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As usual the rules are sometimes applied inconsistently.
An earlier incident in another match the player received a warning for unsportsmanlike conduct which would seem to imply a deliberate act but received no penalty.
During Coco Gauff’s 6-7 (5), 6-1, 6-1 singles victory over Mirra Andreeva on Saturday, Andreev swatted a ball into the Court Suzanne Lenglen stands after dropping a point in the first set. Andreev was given a warning by the chair umpire for unsportsmanlike conduct but no further penalty.
“I heard about that. Didn’t see it,” Bouzkova said. “I guess it just depends on the circumstances and the given situation as it happens. ... It is difficult, for sure.