The
Shield! I've seen that one before.
Look at Me! should be specified that it doesn't make the target creature flat-footed against the Shield himself, considering the target is so focused on the Shield. Turtling shouldn't stack with itself if you don't make use of the counter attack (as in, the extra +4 each time and increasing the multiplier each time), just once is plenty enough. Or limit it to one extra time every 10 levels rather than every 5, so that at level 20 you get a +12 bonus and a x4 multiplier rather than +20 and x6.
Overall, it's pretty good and kicks the Knight in the face as it steps over him to stand atop at a higher Tier level. I'd say it is Tier 4, but likely high up in it. Dunno if it might be enough to really count as a borderliner, but we can always see what others think of it.