5 Shadow of the Enemy Yes, Shadow of the Enemy requires a lot of mana to make work, but there are plenty of ways to get a lot of mana even in Tales of Middle-earth (Smaug would like to give you 14 treasure tokens, just as an example)
I think it might make some lists, for sure
The main function of the new card is the same as the old one - drop your opponent's life total down to something manageable
Depending on what color combination you're playing in Commander, you may not easily have another Blue card ready, but if you do, it's killer
For Magic fans concerned about the potential power of this effect, Its important to note that this card is silver-bordered, meaning it is not legal for use in officially sanctioned tournament settings
Since poison counters are counters, they can be proliferated to get them closer to that magic ten count