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When Planeswalkers were released, in Lorwyn, Wizards needed to dedicate themselves, over the course of sets, to creating efficient answers for them in addition to counterspells

Formats Not Legalstandard Not Legalfuture Legalhistoric Legaltimeless Legalgladiator Legalpioneer Legalmodern Legallegacy Not Legalpauper Legalvintage Legalpenny Legalcommander Legaloathbreaker Not Legalstandardbrawl Legalbrawl Not Legalalchemy Not Legalpaupercommander Legalduel Not Legaloldschool Not Legalpremodern Not Legalpredh Not Legaltlr

You may return any non-Avatar creature card or any planeswalker card from your graveyard to your hand with Overlord of the Balemurk's last ability, not just one you milled while resolving that ability

Those are the sort of cards making these lists more often than not