Cesar Millan recommends using a consistent non-mark (the tsch sound) when a dog is misbehaving. If the dog continues to misbehave, it is important to follow-up the non-mark with some action (e.g. a body block or time-out) so that the dog understands that there are consequences for ignoring a non-mark.
10 Dog-Training Tricks Straight From the Dog Whisperer
Cesar Millan, better known as the The Dog Whisperer, is known for offering tried-and-true dog-training solutions to frustrated, struggling pet owners. Among his most helpful tips are the following 10 that are sure to have even new dog owners leading the pack in no time.