2016 raichu pokemon card 011/032 CP3 1st Edition Japanese Card [Rank A+] – Madgems Colorless Spark Bolt (70+) You may discard all Energy attached to this Pokémon Raichu 2016 reverse holo Pokemon

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The most likely reasons are if its sacrificed, if its legendary and another legendary permanent with the same name is controlled by the same player, if its a planeswalker and another planeswalker with the same subtype is controlled by the same player, if its a creature with toughness 0 or less, or if its an Aura thats either unattached or attached to something illegal

But the sequels names went straight to Gold & Silver

Incapsula incident ID: 679000170039686231-68654725853545550

The Pikachu was the undisputed crown jewel of the set, no pun intended, and its illustration immediately set a new standard for what collectors expect from a premium Pikachu card