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But he doesn't, that's some kind of myth. There was another hit where a Penguin launched himself into Keith later in that very same game. What about that hit on Seabrook from the game before? Just off the top of my head, 3 hits in the last 2 games that are dirty, all with Scott being dressed in both of them. There's been no reduction.
Have the 'Hawks established that mitigation yet? Most teams, including those in the East that are not scouting them as much, see them as soft. It takes time.
And really if you base something that takes time to establish on a small set then you are just being hypercritical.