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Yeah pretty sure the guys who made the movie which Toriyama didn't take much part in just didn't think Goku could easily go Super Saiyan after Namek."Goku becomes a Super Saiyan again." (Passage right next to the film poster). Confirming what was stated on the Toei Return of Cooler info Pamphlet/Film Comic, Goku used SSJ against Frieza, meaning the plot hole is doubly recitified.