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Recently, I have noticed the significance of C Phase in non-SNL or non-SDL approaches. Basically, especially during a day approach when logistics are working against you, comfort and connection are crucial to getting a Day2 with girls. I feel that if you build enough comfort and connection, you can continue gaming by setting up a day2, even without much kino or sexual questions. Then during the day2, you can proceed onto the D & E phases.
However, if you have weak comfort and connection upon the initial day approach, it is very hard to get the girl out on a day2, and you wouldn't even get a chance to proceed to D & E phases of the game.
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