A count may be started at <answer>any time that a wrestler's shoulders are down (both shoulders touching the mat), back-first and any part of the opponent's body is lying over the wrestler.</answer> This often results in pins that can easily be kicked out of, if the defensive wrestler is even slightly conscious. For example, an attacking wrestler who is half-conscious may simply drape an arm over an opponent, or a cocky wrestler may place their foot gently on the opponent's body, prompting a three-count from the referee.
At what point can a count be started? 
any time that a wrestler's shoulders are down (both shoulders touching the mat), back-first and any part of the opponent's body is lying over the wrestler.