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My cat loves tummy rubs. He flops over all the time for them. So long as I pet him on the head at the same time, he's pretty happy. On the other hand, he gets pretty worked up and does the bunny kicks if I bury my face in his belly and rub hard. He also doesn't really let my Dad or younger brother do this, so I'm guessing he's pretty protective about his belly and only rolls over and shows them as a gesture of trust since as another poster said, it's a highly vulnerable spot. The more I rub his tummy, I've noticed the more tolerant he's become. I guess his trust grows with each experience.
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