In this note we show that the asymmetric Prover-Delayer game developed by Beyersdorff, Galesi, and Lauria (ECCC TR10-059) for Parameterized Resolution is also applicable to other tree-like proof systems. In particular, we use this asymmetric Prover-Delayer game to show a lower bound of the form $2^{\Omega(n\log n)}$ for the pigeonhole principle in tree-like Resolution. This gives a new and simpler proof of the same lower bound established by Dantchev and Riis (CCC'01).