That's exactly right, Patrick - you can luff them up to head-to-wind, but no further. The defense here is to get head-to-wind and advertise you have done so. Be honest. <img src="http://www.catsailor.com/forums/images/graemlins/tongue.gif" alt="" />

Edit - The proper course thing will always be dicey and somewhat subjective. Going upwind after the start to the first mark is less blurry than being in the middle of the course on the first downwind... judges I know have told me that proper course becomes crystal clear with proximity to marks of the course, both approaching and leaving. In some cases it is obvious that someone is simply defending a position rather than sailing to the next mark as though the other boat weren't present. That has been the litmus test in protest hearings I've seen conducted.