They do this by specifically mentioning permanents as opposed to nonland permanents or another quality
Debuting in the Kanto region , it was initially only obtainable through glitches or special distribution events, such as the famous 1999 Pokmon Mew Tour
We considered things like legendary sorceries to parallel the single-effect summons, but none of those versions had the resonance of showing them as a creature
But before we just go down the avenue of -1/-1 counters, like sliding in Hapatra, Vizier of Poisons and and Archfiend of Ifnir, think about the idea of using other kinds of counters, even +1/+1 counters that make your opponents creatures better
The tokens can be hidden under other cards or objects, face up or face down, as long as they aren't touching each other