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It seems unfair to judge them on the same rubric as playable cards

The Initiative does not exist at the start of any Commander game

Its worth noting that both Quicksilver Amulet does this without the Creature type restriction, and Dragon Arch does it for cheaper, but only for multicolored Creatures

I imagine your typical play pattern is Warlock Class on Turn 1, curve out with creatures before going to Level 2, and then hoping for a Beta Strike where you get in just enough damage to hope Level 3 ends it

While she can make an excellent Commander for a RW Equipment deck (especially one that wants to use damage-reflection win conditions involving Brash Taunter and Gideons Sacrifice), she is also the kind of smoothing you want in your 99

You give up doing much the next turn in order to do something impactful this turn