If a creature can't have +1/+1 counters put on it, its controller can't choose it just to have it become goaded
I am still in love with that boy, but his interest in sitting cross-legged on the floor of the living room while we pretend we are powerful wizards has waned over the years, and he hasnt played in a long while
As an example, in blue control mirror matches, counterspells become much more valuable as they can make or break a game
In exchange for this higher price, you receive colored mana instead of colorless, which arguably makes Sacrifice much more helpful for powering out huge spells and powerful threats
And it even grants Lifelink
True-Name Nemesis cant grind card advantage the same way that Knight of the Reliquary does, but theres a lot to be said for ramping into a creature that cant be targeted and Knight of the Reliquary has a tendency to get hit by Swords to Plowshares and Submerge fairly often