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istirith
Undead still is limited in power I suppose.
If you're talking about spectres, and even mummies, you're right. But I wouldn't say liches are limited in power, at all. Even not taking into account stacking dam redux that any skilled lich ends up getting, from what I hear some of the phylactories are ridiculous in the skills/power they give. Nobody but mad cheatzorz and former liches would know the list of what you can get out of phylacs, but I wouldn't be surprised if it'd be possible for Satebos to bust out a big AP killer phylac at some point.