Maybe so, but it's still a refuse-able penalty if the offense wants to take any yardage gained...Can't say I remember ever seeing it called on the defense before the snap...only after. Theoretically someone can run off the field at the last second before the snap and they're back to 11, so it's not a penalty until the ball is snapped...right?
It's 12 men in the huddle on offense that is called before the snap.
Sandra