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[10] [11] There are over 1,700 cards in Magic: The Gathering that reference +1/+1 counters, and there are about two dozen mechanics that can put them on creatures

(Create an Incubator token with three +1/+1 counters on it and " : Transform this token." It transforms into a 0/0 Phyrexian artifact creature.) Draw a card

I counted everything mentally, even considering the possibility that Seth might have sideboarded up to more than 60 cards

Usually, they cannot be Special Summoned, and have an effect that returns them to the hand during the End Phase of the turn they are Normal Summoned or flipped face-up (or the turn they are Special Summoned, in case of Spirit monsters that must be Special Summoned)

[2] [3] The number of counters must be represented by the same number of itemsthe numbers on a die cannot be used to represent multiple counters