I compared it to cone of cold and it seems slightly more powerful.The save text saying "Reflex negates and Reflex half; see text" is where all the problems lie, because the text only talks about saving to negate the round 2 and 3 damage and then if that fails a save for half damage can be made each round.
As it stands, you can get a guarenteed xd4 damage because there is no reflex save for the initial attack, but I want to make sure.
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