Sandman vs. Juggernaut

Who wins?

sandman can't hurt juggy and juggy may not be able to hurt sandy.... draw

Thats what I thought. ISnt Juggernaut vulnerable to be hurt when his helmet is off? If so, then Sandman has a 40% chance to win.

his helmets only real purpose is to block telepathic asaults, without it he's still physically invulnerable