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If these guys keep trying to outsmart everyone (like the aforementioned "14 men" strategy) we just might see the oft-discussed-but-never-seen "palpably unfair act" rule. If that comes in, then the ref can pretty much do anything he darn well pleases.
Well it is scary how after one game a cornerback was asked about getting three holding penalties. The reporter was clearly expecting a response of something like “we need to clean up the penalties” but instead answered with something like “we’ll that’s pretty good considering I was holding him all game”

What would the nfl do if players consistently played this game of chicken thinking “I’ll hold you all game because I know they won’t call it every play”