When compared with the in-development card Nightmare which also causes a dead draw but also counters fractals better, I guess Confabulate should be cheaper, maybe 2 unupped and 1 upped.
Still, balancing based on a card that is not necessarily balanced itself might be a bad idea
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Confabulate has the advantage of causing 2 dead draws if you have a
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mark (and I can hardly imagine someone using it without one). But it also has a disadvantage of non-immediate effect.