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PCThe 33 Goudey Gehrig in the link in Tom's post above has the same PSA bar code that appears in the fakes posted by Kevin above.
Is there a way for the grading companies to combat this? Trust in the system has been eroding for some time (it's been a few years since the Wiwag scandal), but if tampering with holders and creating fake filps, etc. is this easy, what's the point.