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Up to three creatures with MV 3 or less has been done at this mana cost, but putting a +1/+1 counter on each of them is pretty huge all said

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Number 13 Language English Legal Formats Commander, Legacy, Modern, Vintage Not Legal Formats Alchemy, Brawl, Competitive Brawl, Historic, Pauper, Pioneer, Standard, Timeless Rulings (8/1/2008) A noncreature permanent that turns into a creature can attack, and its abilities can be activated, only if its controller has continuously controlled that permanent since the beginning of their most recent turn

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