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Personally, I think it would depend on the speed of this movement:
A quick movement- I call it.
A slow movement- I let this one slide but am sure to point out this mistake to the skipper.
If F1 is checking on R1, do you call a balk for any movement of his shoulders no matter how small or slow? If it's slow and only noticable to me 'cause I'm looking, I let that go as well.
JMO
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