I have Amelia lay down on the floor in jeans and a tee shirt. She is not tied up in any way and is free to fight off my wiggling fingers. This change me to use a little and wrestle her into a position where she can be tickled. Her belly and ribs and the main targets. Occasionally I get Amelia's arms above her head to expose her pits. She pushes and thrashes, at one point winding up on her stomach. Unfortunately for her she is less able to fight back in this position, and I take full advantage. Always a fun time with extremely ticklish Amelia.