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He is untied and free to move about with complete control.
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His hands are chained/tied up or handcuffed behind his back to prevent his covering his balls.
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His legs are tied open or there are leg spreaders to allow her direct and easy access to his balls.
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His hands are both tied/chained up AND his legs are forceably spread wide for her.
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He is blindfolded and never sees it coming thus is unable to jump or move out of the way.
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He is both blindfolded and tied denying his knowing its coming while giving her the easiest access.