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When I see this in lists, it's usually a combo piece

X rule: When this Pokmon is out the opponent takes 1 prize card

Mook Maker: Number C43: High Manipulator of Chaos has 0 ATK and no inherent way to increase that stat, making it fairly unlikely that it will be attacking the opponent or their monsters on its own

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Giratina VSTAR (Lost Origin) Weve included several VSTAR cards in our list as some of the most noticeable losses with the F Regulation Mark fall into this category