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Even if WotC owns the artwork by assignment, rather than as a work for hire (both possibilities were discussed in part one of this series), it is still unlikely that MTG art would fall under VARA protection, because the artwork as printed on cards, is not in a limited quantity and not signed by the artist (though the original works, like oil paintings, which the card arts are derived from, likely are protected under VARA)

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But building a Commander deck has also become an increasingly complex process

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is easiest & is pretty much unobtainable