This is VERY annoying to get...
...ok, obviously you know that to get it, you have to kick out of a pin when you have two limbs with red damage. This is quite easy to accomplish, but is also quite hard as you could get pinned by your opponent whenever you have one limb fully damaged...
...but once you have accomplished this, just let your opponent hit you with strong grapple moves, as they'll probably try and pin you after hitting you with one. (If you get hit by a finisher however, you're stuffed.)
Now, i just thought of something, maybe, if you get two limbs fully damaged in a tag match, and your tag partner breaks up the count at two, you may get the ability. Now i haven't tried it, so don't blame me if you try it and it doesn't work. But its just an idea which popped into my head.
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Rich's first ever Super Smash Bros Brawl Wi-Fi Opponent