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I've found that when they play on their back, they get so excited that nipping just can't be helped. My 40 yr old hen very rarely bites too hard when on her back,but still does. Usually all i have to do is tell her "easy" and she good, but if i get too rough ,she does too. Of course we like it rough, LOL
I'd probably had Jake for about 20 yrs before she started flipping over on her back and playing. Since then i've started younger birds doing it and it really is something they do naturally. Just took Jake to show me how much they like it.