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Pumpkinhead's tier

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I see Pumpkinhead is listed as a tier 9.

I was curious what all factors go in to tiering. I read the tier description, and seem to understand it; however, Pumpkinhead is said to be an immortal demon of vengeance. The body of Pumpkinhead is simply the vessel in which the demon inhabits; if you were to destroy the body, his consciousness would simply take another form. It is not known (to my knowledge) if the demon can actually be killed or how powerful he truly is in his true form.

With that said, what criteria were considered in the ranking of Pumpkinhead? His tier is on par with an average, trained human, but when You read his actual feats, powers and abilities, then it's quite apparent that he's superior to a tier 9 human.

Is it his lack of destructive capabilities, lifting strength, and other factors that keep him as a category 9?
 
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