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Its ability triggers on any zombie you control dying, not just nontokens, so the 13 zombies you make off Army of the Damned or decayed ones off Jadar, Ghoulcaller of Nephalia all trigger its mega-surveil ability

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He then won Obelisk the Tormentor from Kaiba during the Battle City semi-finals, before claiming The Winged Dragon of Ra in his final duel against Yami Marik

Some in the comments are even suggesting that this estimate is too modest