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If you've let someone get that close, it's moot which position your gun is in.
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With SUL I can simply retract my firing arm into retention position and parry/block with my support hand.
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He did point out you're in a better position to counter than if you're in SUL or any of the low carry positions
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I don't agree. With the elbows bent as Gomez advocates an adversary can easily drive the gun into your face - with bent elbows you don't have the strength to effectively resist. If you bump into something (or somebody bumps into you) the muzzle is in your face. Also with the muzzle elevated it's easier for an adversary wrestle it out of your hand.
IMO SUL is better for maneuvering around people in close quarters and Gomez's method is good when you're not in close quarters.