Intoxicated Rating Sales
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Have you ever witnessed anyone just practically give away a ton of Rating points in one night? Then of course, you play them the next day, when they are sober, serious and looking to get back where they were. This is one reason why I always use a Rating range when getting a game, with the bottom end as close to my own Rating as possible. The player is not "cheating" or even intentionally "sandbagging," but still you can lose points unnecessarily. I am glad chess.com lets us choose by Rating who we want to play. Of course, in a Tournament, I guess you have no choice.