The P19 can't luff at all.
"17 ON THE SAME TACK; PROPER COURSE
If a boat clear astern becomes overlapped within two of her hull
lengths to leeward of a boat on the same tack, she shall not sail above
her proper course while they remain on the same tack and overlapped
within that distance, unless in doing so she promptly sails
astern of the other boat. This rule does not apply if the overlap
begins while the windward boat is required by rule 13 to keep clear."