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In page Hastings 1895 chess tournament:

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Black cannot capture the white rook: 22...Qxe7 23.Rxc8+ Rxc8 24.Qxc8+ Qd8 25.Qxd8+, etc. and White wins with his extra piece; while 22...Kxe7 23.Re1+ Kd6 24.Qb4+ Rc5 25.Re6+! wins as well (the often-mentioned 25.Ne6 doesn't amount to much, for example 25...Rc8 26.Qf4+ Kc6 27.Qa4+ Kd6). White's replies are also limited, however, because Black is threatening mate with ...Rxc1, as well as threatening to capture White's queen and knight. In order to prevent ...Rxc1, Steinitz's rook now "thumbs its nose" at the black king: repeatedly checking right in front of the king, which cannot capture it.