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Also, the cards in your 99 all have to have a printing at common rarity, in a nice callback to the Pauper format

Given the raw strength of the card, five mana is fair as a casting cost , but if you can keep it on the battlefield beyond your turn, that five mana more than pays for itself

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To make the card even more treacherous, it could be followed up with another Song from the Whispers in the Well expansion, "Can't Hold It Back Anymore" , which takes all damage counters and moves them to one chosen character

and I think if we had a linear five-color human general, it would equally weigh on Commander as well