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If something is 'downed' it means it has been subject to or is undergoing an active process.
In fighting, a 'downed' opponent would normally refer to someone who has been knocked down, or who is being held down, or who is unable to get up.
It would be fair to say "you can't knee a downed opponent in the head".
But someone who is choosing to put their hand on the mat isn't "downed", they aren't being "downed", they haven't been "downed".
I'd suggest the athletic commissions misinterpreted the term a long time ago, perhaps it would be better if you could knee an opponent that is choosing to be on the floor - ie, someone butt-scooting, or putting their hand down, or resisting being lifted up?
You guys think that would be possible, or is it just too difficult for a referee to interpret when a fighter is "downed" or just choosing to be down?