afore mentioned bubble wear. Not every figure stays perfectly still in the package.
Just imagine what grade you'd get if your figure lost the oring once you shipped it to them. YOu get it back and it's a 65.
Oh, that would suck! I have a Starduster in a sealed bag. THe bag has a tear on the corner so I was going to send it in. The figure is perfect with absolutely zero wear, probably because it was in a bag and not a bubble. However, after seeing other bagged figures (Heavy Metal, Hasbro direct Hawk, Grand Slam, Steeler, etc...) mostly get 85's with no apparent wear I've decided not to. I'd be very upset with anything less than a 95 due to the case fresh, untouched, perfect state.