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When it eventually dies, you can move those counters onto another creature before shuffling it back into your deckensuring those counters never go to waste

Theres the usual balance considerations of other formats, but also things like whether or not a card promotes unhealthy play patterns for a four-player casual format

In addition, he has Whenever a Human deals damage to you, destroy it. which cant be ignored since Humans are the most common creature type in Magic

Which screams combo deck, and there's any number of ways to win off of that

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I clearly wasnt alone in this line of thinking, because Black Market and Pawn of Ulamog saw an absolute ton of play during Commanders early years, and the former was actually a chase card for a while since its only printing was in Mercadian Masques prior to the release of Commander 2015