Absolute pish.
Hes an utter shitebag, and that doesnt change just because someones done a shitebag act on him. The amount of times we have, Wotherspoon in particular, mark him, only to spend the ninety minutes getting clattered off the ball and forearms in the puss as they lie on the ground after going for a header is unreal. "Fair game" though, I suppose, because Browns been up to that for so long so it must just be what happens.