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Hence, all you can do is bow down against this spell if ever it ends up being put into play, because unless you're able to counter it or remove it as it goes into play, you're smoke

I cannot emphasize enough how trivial this requirement is in Commander

Find Another Way Return one or two target permanent cards from your graveyard to your hand

You gain life equal to its power

The effects of the Phyrexian Devourer is quite true to its name, where you control, to a degree, what the Phyrexian Devourer consumes

While effects like No Mercy destroy the attacking creature specifically, Michiko Konda has the possibility to start forcing opponents to sacrifice other key permanents, like their mana rocks or lands