FILE - This is a Dec. 11, 2009, file photo showing Orlando Magic center Dwight Howard, left, being fouled by Phoenix Suns center Channing Frye, right, in the first quarter of an NBA basketball game in Phoenix. The 'Hack-A-Howard' tactic is becoming an every game staple for the Orlando Magic, with opponents sending the big man to the free throw line every time he's around the rim.
(THE ASSOCIATED PRESS/Paul Connors, File)