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I guess so. To me, unfair = "illegal by the spirit of the rules". In this sense, strategic fouls = unfair, because they give an advantage not intended by rule to the fouling team, even though the team is punished by conceding yardage. Safety fouls and UNS are also unfair (in that sense, and in the conventional sense), because those fouls cause harm to the victims and/or provoke retaliation. This is why Automatic 1st Downs are assigned to fouls by B that fall into the "unfair" (illegal by spirit of the rules, unsafe, or unethical (UNS)) foul categories in NCAA and NFL rules.
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