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Depends on your definition of substantially. It is harder to reach a 20% ROI at the 22s. If I was to make a guess a 20% ROI at the 11s translates to perhaps 15% in the 22s.

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I'd say that's about right.

I made a big deal about moving up but really it's been dead easy. They are definitely harder but if your a solid 11s player you'll have no problems beating them for a good roi.