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The ambiguity of what lay and pray actually happens to be is well illustrated by comparing the Khabib v. Healy fight and the Carmont v. Phillipou fight. Carmont was relatively active from top position and was undoubtedly the superior fighter. Carmont got endless shit for pretty much dominating Costa using his wrestling and top game. In the third round of Khabib v. Healy, Khabib thoroughly outgrappled Healy, having him on his back for the majority of the round. He was relatively active, as well, though no more than Carmont was. Khabib was almost universally lauded for what he did, whereas Carmont was incessantly called boring.