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At the absolute top of the rarity food chain are Ghost Full Art Cards in TCG Card Shop Simulator

Then if you control ten or more creatures, you may play the exiled card without paying its mana cost

Here are all the new Warhammer 40k Magic: The Gathering Universes Beyond cards for the Imperium, Tyranids, Chaos, and Necrons commander decks

Rival ink colors like Steel would need to expend a precious copy of And Then Along Came Zeus to efficiently deal with Hero to All, while other ink colors would need to find a way to directly banish this heavy hitter if trading via challenges looks to be a losing proposition

For pure counterspell cards I think 0-3 is fine