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That's actually incorrect. The Phantom Thieves in Strikers are much weaker due to being rusty and the fact Igor is not present, meaning Joker can't access his strongest Personas. That statement there is just for gameplay reasons it seems.Or maybe Yu just canonically got to level 81 in Naoto's dungeon in the anime? Or that the level number is just a game mechanic because the Phantom Thieves in Strikers are at full power but are like level 5 at the beginning of the game