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#20
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There are several cases of this prior to 2006. In 2006, though, MLB only gave license to Topps to make RC cards of players that had made the 25 man roster. This was to cut down on the prospect filled sets (Bowman now gets around this by calling the prospects an "insert" set, though most collectors buy it just for these cards). This is what caused the 2006 Alex Gordon Topps card to become a SP with variations made to remove Alex from the set.
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