I think that it is a mistake to causally equate a large amount of secondary axis tilt with hitting upwards at a teed ball when using a driver.
Here is a capture image of VJ Singh from a swing video.
VJ Singh always hits down with his driver - note the forward clubshaft lean. However, he has a large amount of secondary axis tilt.
I think that a large amount of secondary axis tilt in long hitters (like Tiger Woods and VJ Singh) better correlates with a need to keep in balance when swinging at fast arm speeds.
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