This is another type foul that I think needs to be reviewed in real-time, just like they do with the process of completing a catch to determine whether or not someone had possession of the ball or not. It is so late when he lowers his head it's more of a reaction than anything. His head goes down at the absolute last millisecond, and I disagree with you in the fact that I believe if his head was up and he made contact with the helmet of the receiver, he still would've gotten called for targeting. I think he saw the trajectory he was on and instinctively tried to not hit the receiver in the helmet, thus lowering his head. Also, if lowering the head like that is flagged for a penalty, then why not this?
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