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In the case of Pikachu EX, Giovanni lets it hit for 100 damage on a full Bench, allowing it to knock out certain pesky Stage 1 Pokemon who would usually just escape its reach

Reshiram ex BWR [SV11W 174/086] Similar to Zekrom ex, Reshiram ex delivers another sleek monochromatic masterpiecebut its the recent discovery of a misprint that has truly set this card ablaze in the collectors world

Maybe special constructed events that award cards (like Singleton or Momir) could also have one of the Uncommon rewards be protected

Then each enchantment card in your graveyard has escape equal to it's cost and then three exiles

Exactly 100 cards including the commander