TXMike,
Here is what I was told: If the Defensive Back, has his back to the ball, he is allowed to extend his arm (no contact and no interference); but he is not allowed to wave his arm back-and-forth continuously, with his back to the ball. (no contact, but interference) That made it an act to deceive, and would be interference.
This was about 8 years ago, and by a Big East official.
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