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I used fortitude in the first two weeks of floor events. Once on Apocalypse, and once on Leader.
Leader is awesome with Fortitude!
Just like Emerald Eye of Ekron, I'd never play him without it. He's just too darned fragile, and Wildcarding the Bat TA with the hopes of staying in Hindering the whole time (and hoping that no enemies have Outwit and access to Ultimates / Superman TA) is far too restrictive a plan.