51, but there's a substantial degree to which it depends on your weapon too. A lot of heavier weapon classes make you far harder to flinch when you wield with both hands and attack, and colossal weapons do it even one-handed, so those classes of weapons are the ones that allow you to trade hits most often

That's a big part of why I stopped playing, honestly. Waiting two years for a window to attack, just to use light attack once before waiting another two years- then if I get hit by the lightest tickle, I just fall to the ground and am instantly punished. So boring compared to DS imo.