I would believe so. A shallow climbing turn to maintain visual contact, or extending away to discourage pursuit. Since the fighters are probably at cruising speed, zooming is probably not an immediate option for the lower fighter. Another problem with zooming is that while it does trade speed for altitude. When you come out on top, you have little energy(speed) left, and if the higher bogie has turned to engage, you are probably in a whole lot of trouble...or soon will be. I would think a shallow turning climb would be in order both to gain altitude while retaining a reasonable bit of energy and to maintain visual contact with the enemy. If they enemy is diving towards them, they may very well be. And if the bogie engages while they are zooming? The lower fighter has just bled off most of his energy. By maintaining visual contact, the pilot can attempt to counter the bogie with his own counter. There hardly ever is a 'straight' attack in the final moments of the air 'dancing' duel. That only happens when the bogie does not see you coming.