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Killer wasn't the arc villain and the fight wasn't consequential to the story to the same extent. Caesar was the arc villain.

The initial fight between him and Kaido was the BS, not the current fight. It's called arc hype, remember when Caesar stopped Luffy, and Yeti Cool Brothers stopped Zoro? Serious end of arc fights are what powerscaling should be based on, not low end feats from when Oda is trying to hype villains...