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My thought is that it is nearly impossible to tickle someone that is actively wrestling against another wrestler. The spasms that tickling cause are not likely to happen when an athlete is actually wrestling. Now, having said that, if a wrestler was trying to do something like that during a match my inclination would be to penalize them for unsportsmanlike conduct. Any maneuver that is designed to punish rather than complete the goal of pinning a wrestler is illegal. Pretty hard to make the argument that "I'm trying to tickle him to his back"
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