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This might be via equipment with a commander like Ardenn, Intrepid Archaeologist, or by stacking counters with the likes of Ezuri, Claw of Progress

When you combine this with #49 Mindslaver, #67 Memory Jar, or even something as silly as a Panic Spellbomb, you have problems

Now it's easier to meet the conditions with support such as his GY fertilization and treatment of cards with the same name, but at the same time it's easier to exclude his GY cards, so it's a zero point evaluation