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Originally Posted by Lupo
Yes and they're called "cheating" or "adversarial GMing".
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First: We're discussing Dungeon Fantasy, which is explicitly a somewhat adversarial style.
Second: It's neither cheating nor adversarial for the GM to create situations in which limited DR isn't as good as non-limited DR. The player has paid less for his DR; it should be less good. It's cheating for the GM NOT to run into situations where your Tough Skin is less useful, because if you never do, you've gotten something for nothing.
Kromm's example of a 1d stinger with a 3d followup is an excellent one. Tough Skin also won't protect you against:
-The HT penalties on Water as-Sharak's 'Ocean's Frozen Spray' ability or that of an Earth as-Sharak's 'Desert's Sand' ability;
-An Erupting Slime's Slimeball attack;
-A Frost Snake's 2d toxic follow-up, which will affect you fully even if its 1d bite is stopped to exactly 0 points by your armor;
-A Toxifier's Toxic Attack.
That's just from the stock monsters provided in DF2.
Tough Skin is not a free limitation.