as it stands it is a counter to fractal, pharoah, FFQ, aflatoxin, and boneyard, but it is a way way way way WAY to OP of a counter,
Edit: maximum of 73!!!
dont forget fly weapon momentum, and only shields capable of blockin THAT much damage are, dusk shield, fog shield, phase shield, and bonewall, only 2 of which are common in decks