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I think it's probably pretty fair. The niche-defense stuff isn't usually that expensive in that, in any fight in which someone isn't trying to kick you, Footwork is entirely useless, and even in fights where someone is trying to kick you, they likely still succeed -- just a little bit less often. Whether Desperate Improvisation can be used in a given fight is a little more in your control.
And don't get me wrong, it's a gimmicky edge but it's a potentially really powerful one in the exact right situation. Granted, in that situation maybe you should just be running away instead, but if you didn't, you might just kill everyone and walk away looking like a boss.
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