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I think those eBay auctions that say "1090-1911 Evers Portrait PSA 5 - EXCELLENT!" and then in the auction you see that it is actually a PSA 5 (ST) or (MK) are the ones that piss me off the most. They are just banking on someone bidding on the title alone and overlooking that the card is worth 1-2 grades less in value.
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JP,
I was thinking the same thing. Also, on newer cards when the seller says "fresh out of the pack" and the card has dinged corners or some other defect.
Also, reprint cards that don't say "reprint" in the title. They really irritate me. It looks to me like they are hoping to find some sucker who doesn't read the description and thinks it may be real.