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Permanent spells that were countered earlier in the turn never entered the battlefield, so they won't be legal targets for Brought Back

Part of the issue for these players is that while some decks can make use of their graveyards, for those that don't, the counterplay against Mill can be hard

This is an incredibly powerful card when used fairly, but it is extremely easy to break

Enchantment Color tag templates(None) Spelltithe Enforcer Whenever an opponent casts a spell, that player sacrifices a permanent of their choice unless they pay

Theres also something fun about making your opponent make the call on the flip that could decide the game