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You can then later sacrifice it (which sometimes requires a mana cost) to generate an effect that scales based on how many counters it has

First strike and counters isn't bad by any means, but landfall is a pretty competitive archetype

III Starting with you, each player chooses a creature

It was a random printing in a Commander deck that found its way into the Legacy and Vintage Cubes on Magic Online where players realized Laelia had a lot of potential as an aggressive creature with a great exile payoff

They all think that keeping mum, that shredding their documents, that tossing knowledge down trash chutes and into rat-infested sewers is good enough to cover their trails

On top of being hugely popular in Pauper, Mental Note also sees a strong amount of Commander play