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He made a lot of squicky moves on Yuma through his disguise of Shingetsu Rei and a multitude of lies, and his duel with him showed his commitment to completely burying the heroes for defeating him that one time

Game & Watch Cards

C Common Cyber Phoenix X FIRE Level 4 [ MachineEffect ] ATK 1200 DEF 1600 While this card is in Attack Position, negate any Spell/Trap effects that target 1 Machine monster you control (and no other cards)

Joe can play his Personal Weakness event "Unsolved Case" even if he doesn't have clues, as removing the card from the game is considered a "change in the game state" and doesn't require him to place a clue on the highest shroud location beforehand to be allowed to resolve that effect