I ship every card whether it sold for 99 cents or $999 in bubble envelopes. It doesn't matter what the card sold for. To the buyer, that particular card is important to them and they expect it to arrive in the same condition they bought it for. The PWE offers no protection and if I received a card in a PWE, I would be pissed.
I have received cards from AH's that were wrapped in paper towels or placed in glad bags. Even though they dropped it in the box, to me it was just not professional. Made me think twice about buying from them again.
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