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"So I've seen quite a few people complain here that amiibo are on-disk dlc locked behind a big paywall." I doubt you've seen anyone contend that the amiibos themselves are on-disk dlc locked behind a paywall, but that the content locked to amiibos is. And on that notion they are by definition correct, regardless of the main reason that people buy amiibos.

You can suggest that the content isn't very meaningful, but it is by definition:
"on-disk"
"dlc"
"behind a paywall"

And if you don't mind that that's fine, but they are what they are.



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