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If the receiver is making no attempt to block, (i.e., is not using his hands at all), and is simply trying to get around the defender to run his route you might have a case for defensive holding (or PI if the pass is in the air), if the defender is using his hands. If the defender is quick and is simply blocking the path of the receiver with his body then I would tend to call that good defense. The Demetriou book "Judgement Calls" has a good section on this type of scenario. Also some other good discussion on other judgement situations.
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kentref
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