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Because TrueQuartz [The Grave of Enkindling]


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Sadly, "as a result of battle" isn't the only way a monster can be destroyed these days. Sure, you can try to pull a kamikaze attack, but there's always that threat of Fiendish Chain, Book of Moon, Dimensional Prison, Sakuretsu Armor, and even cards like Mirror Force, Scrap-Iron Scarecrow, and Negate Attack, even if those aren't used as often/at all.

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