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steve kI think most bidders are basically immune to auction words such as rare, scarce, etc., etc., and as Jay pointed out, the seller risks their credibility on the listing. Jimmy admittedly stated that he was hoping that using the word rare would get bidders more interested and then hopefully resulting in a higher price. Sometimes it works and sometimes it doesn't - that's marketing and is the choice of each individual seller. You see this style of marketing hundreds of times each day in ads for products on TV and in the newspapers.
A better way, rather than using biased descriptive words, would be to just list a current price guide figure for the card in that grade. Then a prospective bidder can decide for themselves if that $20 book list common is considered a "rare" card. Of course sometimes sellers will state that a listed Fair condition card books for $1,000 in Near-Mint condition as if that $1,000 book price had virtually anything to do with the real value of that Fair condition card.