I don't do kick counts unless I haven't felt her move a whole lot. Then I drink some water or juice and lay on my left side with my hand under me and she typically will get the 10 movements within about 3-5 minutes, max.

I never did kick counts, only because he was pretty active. If it seemed like he didn’t move for awhile, then I would lay on my left side and kick count. I only had to do that once.