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The chances of an opponent having three or more creatures on the field is pretty high, especially with all the token commanders running around these days, making Defense of the Heart a delayed but powerful creature tutor

That's because he's the go-to commander for a niche but amusing strategy, attacking with walls and other Defender creatures

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They resolve even if that ability is countered

With so much removal spells focused on Creatures, Artifacts and Enchantments, Planeswalkers can easily overrun the table with value, making it one of the most powerful decks in Commander