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wait does that necessarily mean obscure historical figures will always be phantoms or no? (can very obscure historical figures be servants or will they always be phantoms/wraiths)
Even obsucre historical figures are far more known and widespread than a urban legend. But the specifics are never completely revealed, and are probably not actually a thing set in stone to begin with. Paul Bunyan is a Servant, I mean... does anyone outside of USA/Canada ever heard of it? There are a lot of examples of legends/stories that are really only relevant in a specific country/regional cultural sphere that are Servants.
At the same time, in Shinjuku, we had the appearance of Round-Faced Priest, String-Fiddling Old Man, Shaggy-Haired Professor, Straight-Laced Gentleman and Belgian, all as phantoms. Father Brown (Priest) and Hercule Poirot (Belgian) are both pretty famous, I would definitely said far more famous than Paul Bunyan, but still lacked the spiritual base to be Heroic Spirits.