Let's ask it a different way: when does 13 apply?

I contend that L can luff to the moon, without tacking, while keeping clear. The only rules that apply are 11 and 16.1. 13 doesn't apply until L crosses head-to-wind, correct? If that's true, L can luff, W would likely tack away, then L can tack and follow.

This all started as a discussion about mark-room. L can't do the above maneuver while she owes mark-room to W. However, that is a finite area, and L is free to luff as soon as W passes the point where luffing would put W into the mark or prevent W from tacking to round the mark as the inside boat.

Mike