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    Tsukuyomi

    Kakashi was weaker in P1, and being a non-Uchiha, despite having a Sharingan, it's harder to break. It's easier if you're a pure-blood Uchiha or have Mangekyo. That being said, there are definitely other Shinobi out there who could break out of Tsukuyomi if they are skilled enough with chakra...
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