[Jim S]

Mike's comment about "making an effort to break contact" is the key. If the player being 'held' is just trying to run through theh "holder" then it really doesn't make a difference.
I even had a head coach last year make a great comment to one of his players. The kid was being "held" right in front of both the coach and me. When he started to complain the coach said "Why should he (me) call it? You weren't doing anything about it!"