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Villain Forgot to Level Grind

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"Dear brother, you're becoming predictable... I trust you, you betray me, round and round in circles we go. See, Loki, life is about growth, it's about change, but you just seem to want to stay the same. I guess what I'm trying to say is that... you'll always be the God of Mischief, but you could be more."
Thor (to a tasered Loki), Thor: Ragnarok

Surprise! It's an enemy ambush! In fact, it's that nasty minion from before. Apparently, he's decided that he wants to fight the heroes again. And he's just as strong as before! Oh, This Is Gonna Suck!

Oh, wait. He's literally just as strong as before, not any stronger at all.

It seems that there was an intelligence failure on the villain's part and he's failed to consult the Sorting Algorithm of Evil before attacking. As a result, the heroes have increased in power while the villain has stayed still. He was extremely dangerous the last time, but the heroes have been Level Grinding and improving their skills so much that they now have him outclassed. Which begs the question, why didn't the villain use the time to improve and keep his lead over the good guys?

As a video game trope, an example would be a Final Boss Preview kicking your party's ass when you're level 10, but when you come back at level 50 he's a pushover. It can even occur in some games where enemies level up as you do, as long as there is a ceiling on how powerful they can get. This trope just means that after a certain point in time, you eventually outlevel the villains and curb-stomp them as a result.

Outside of gaming this be justified if there is a known limit on someone's abilities. If the bad guys max out at 50 and the good guys have the potential for 100 or more, then it's only a matter of time before it's Time to Unlock More True Potential. If the bad guy is a Threshold Guardian the whole point could be that they're offering a set challenge to allow people who meet it to pass. Similarly, it may simply be that the heroes, while initially weak, have training resources (like a uniquely talented martial arts instructor) that the villains don't.

Otherwise if enough years pass between battles, you could say that the heroes are young and untested while the villain is in their prime in the first encounter, and by the second encounter the heroes are in their prime and the villains, despite having the same bravado, starting to slow down in their old age.

In some genres, particularly the Superhero Genre, it could also be that villains, particularly those iconic villains with Joker Immunity, may simply lack the opportunities that the hero has to grow stronger, particularly if the hero has beaten them and locked them up in prison, where there are much fewer opportunities to level grind and grow more powerful as opposed to the hero who's free to roam and go on many more adventures against different adversaries to better himself and his abilities. For certain types of villains, particularly those of the mobster variety, running their criminal empires and making ill-gotten profit will always be at the top of their priorities even if they're out of prison and thus, keeping up with the hero in a fight won't always be their top mission objective. Another possible justification could be that if the hero has to fight a lot of villains who fall under the "criminally insane" category, many of them won't be operating with a full deck of cards to begin with and as a result, don't really possess the same rational mind or mental facilities of the hero to improve themselves through martial arts or any other form of power-building.

Compare Can't Catch Up, of which this is a villainous version. It can also be a subtrope of Villain Decay as a means of justifying why a once threatening foe is no longer dangerous. This could eventually lead to an Ineffectual Sympathetic Villain.

See Also: Sliding Scale of Villain Threat. Compare Strong as They Need to Be for an aversion, when the heroes are artificially weakened below the villain. Also compare The Worf Effect. Contrast Villain Decay, where a villain becomes less threatening for potentially less well-defined reasons, Monster Threat Expiration, and Villains Learn Faster. Might overlap with Degraded Boss, whether on purpose or not. Inversely Contrast Snowballing Threat for when the villain actually level grinds faster than the heroes.


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    Action Adventure 
  • The Castlevania series gives us a few examples of this. Notably, some early bosses in Symphony of the Night, such as Slogra, Gaibon, Werewolf, and Minotaur, are encountered later in the game, but with the same stats as before, and are considered normal, respawning enemies. Of course, with your stronger weapons and abilities, they are not nearly as difficult. Even when you're fighting as many as four of them in the same room.
  • Devil May Cry:
    • Devil May Cry 3: Dante's Awakening has a more plot-oriented example. Vergil goes from handing Dante his ass during their first encounter, to fighting him to a stand-still in their second, and finally losing to him in their third. However, it's not so much that Vergil forgot to level grind, since he actually gets progressively stronger just like Dante, gaining new weapons (Beowulf, Force Edge) and attacks, but Dante's just gaining much faster than he is. History repeats itself, chronologically speaking, in the original game: Nelo Angelo proves himself Dante's superior in their first battle, but Dante wins their second before slaying him in their third. Thematically appropriate, as Nelo is Vergil.
    • Vergil's attempt to avert this and power level is basically the plot of Devil May Cry 5. After losing again and again Vergil resorts to desperate measures to have the power to defeat Dante. First he separates his human and demonic halves apart with Yamato, then his demon half uses the tree that gave Mundus his power to become even more powerful than Dante. That actually works and Dante is given his worst defeat to date. Dante unlocking the power of the Sin Devil Trigger turns the tides again but that allows his human side to recombine themselves back into Vergil. The returning Vergil and Dante end up breaking even until Nero appears to tell them to knock it off.
  • The Legend of Zelda has this for Recurring Bosses:
    • In The Legend of Zelda, a completely unaltered version of the Level 1 boss (Aquamentus) returns guarding Level 7. With the best sword in the game — which is obtainable by that point — it can be killed in one hit, and the Magical Shield can block its beams.
    • The Legend of Zelda: A Link to the Past: The rematches against the Light World bosses in Ganon's Tower are really easy because by this point you can have the Master Sword and the Silver Arrows.
    • The Legend of Zelda: Majora's Mask: Wizrobe appears multiple times and is easier to defeat in later fights when you have Light Arrows, especially if you use Chateau Romani.
    • The Legend of Zelda: The Wind Waker: The rematches with Gohma and Kalle Demos are significantly easier, as while you're stripped of any items you didn't have when you fought them, you do get to keep the fully-powered Master Sword, plus any and all life upgrades you've collected along the way.
    • The Legend of Zelda: Skyward Sword: Moldarach first appears as the boss of Lanayru Mining Facility, and reappears later in Lanayru Shipyard... after your sword has been upgraded to do double damage, making the boss much easier to kill.
  • Metroid:
    • Metroid Fusion: The SA-X. Justified because it possesses the thing that can completely screw you (the Ice Beam) if you ever cross paths. Only after you get the Varia Suit (to block the freezing) and the Plasma Beam (to pierce the armor and hit the softer X core) does it lose its edge against you and Samus becomes able to beat it.
    • Metroid Prime 3: Corruption: Berserker Lord is the first boss fought in the game and, while by no means difficult, takes some time to defeat as it's one of the two (the other being Meta Ridley) Samus has to confront before acquiring the Hypermode powerup. It returns later in Elysia and, as soon as its weak point is exposed, it can be killed near-instantly now that Hypermode is available (as the monster hasn't received any sort of upgrade or improvement, unlike Meta Ridley who returns later in a stronger form as Omega Ridley).
  • When you first fight Genichiro in Sekiro: Shadows Die Twice at the end of the prologue, he's a Hopeless Boss Fight that outmatches Sekiro in almost every way. When you fight him again around the end of the first 3rd of the game, he's a tough boss fight and the first with three healthbars, gaining an extra over the standard two when he removes his armor and starts to throw lightning around. When he's again at the end of the game, he remains in his unarmored form and has a measly one healthbar, and despite him gaining a few new attacks courtesy of his own Mortal Blade, he's no match for Sekiro. He acknowledges this when you defeat him, and kills himself with the Mortal Blade, becoming a vessel to summon Isshin Ashina at his peak back from the dead, who acts as the real final boss.
  • The first round of bosses in Terraria are a real challenge, particularly the Wall of Flesh. Once you reach hard mode and acquire its dramatically more powerful gear, they'll come off like pushovers. For comparison, the final normal boss has 8000 hit points. The most fragile hard mode boss has 28000 as of 

    Action Game 
  • In Mega Man X6, the first battle you have with High Max is an automatic loss. No matter what you do, he cannot be damaged. Of course, as you go along the game and subsequently encounter him again, he will be damageable by a few weapons you acquire from the boss Mavericks.
  • Mega Man ZX: Aeolus and Siarnaq intercept Biometal Model A at the Tower of Verdure with the intent to claim Model W; even though both of them are together, Aeolus decides to let you off the hook, confident that he can "end you at any time". How wrong he is when you fight him proper. The last time you see them before the Final Boss, however, all four Guardian Biometals show up in the same room with singular intent to shut you down. It would have gotten messy had Biometal Model X not shown up to provide a diversion for you.
    Siarnaq: Tactical advantage four to one. Commence complete destruction of target.

    Beat 'em Up 
  • This hits Benny and Clyde in the original River City Ransom and its remake in their second appearance. In their first appearance close to the first shopping center, as a duo they're fairly strong, about on par with Moose, the first required boss (who lies in wait a few screens further ahead). Beat them at their original hangout, though, and they'll reappear later in the game next to the sauna, one screen away from River City High, with the exact same stats as their first appearance. A player that has grinded out one of their attack stats to the max as well as picking up the associated Rapid-Fire Fisticuffs move (both rather easy to do by this point) will take them out in one or two hits each, effectively turning the duo into a Piñata Enemy.

    Card Game 

     Grand Strategy 
  • Fallen Empires in Stellaris: they have fully colonized systems and very powerful fleets before you even get out of your home system, but they never actually manage to improve by virtue of having given up on their imperial ambitions. They also don't bother to replace any of their losses, so if you manage to damage their fleets by destroying some ships, those fleets will retain their reduced combat power. While the 100,000 battle point fleets are intimidating in the early and mid game, by the end game, they're barely worth worrying about, and Fallen Empires can become Fallen Vassals pretty easily as a result. However, if they're angered enough to become an Awakened Empire, all bets are off, as they start colonizing and dominating with their vastly more advanced society: if you're not at the end game when it happens, you'll be steamrolled quite quickly.

    Massively Multiplayer Online Role Playing Game 
  • In City of Heroes, Frostfire, the first Elite Boss most heroes will encounter, later appears in several tip missions, although by that point he's become a regular boss (which means depending on your difficulty settings, he may even spawn another tier lower, as a lieutenant). A hero morality mission also features Nocturne, an archvillain from the Faultline arcs, as a regular boss.
  • Final Fantasy XI: Averted in many fights. Instead of having the fights based off of your level, your level is restricted in several missions as well as optional "BCNM" fights. Recently, most of the mission fights had this restriction removed, due to the lack of players willing to help as well as the difficulty level.
  • Occurs with Zenos in Final Fantasy XIV Stormblood: At the beginning of the expansion, he takes damage, but when push comes to shove, he easily blows you away sends you flying. When you fight him later in the expansion, the same thing happens. He then goes on to find a new sword that he likes, which does ostensibly make him stronger, but he doesn't nothing to improve his abilities, such that when you fight him at the end of the expansion and he unleashes his powerful "blow you away" attack, it doesn't even phase you anymore, and he ends up losing the fight.
    • Likewise in the following expansion pack, Shadowbringers, The Dragon is completely immune to damage whenever you fight him, forcing you to run away. By the end of the expansion, he makes a Last Stand to stop you, and summons even more power to do so, but fails and is defeated decisively. The fact that you're almost literally exploding with absorbed Light energy is likely why he doesn't stand a chance.
  • RuneScape:
    • In "Legends' Quest", the player must fight the same demon three times. Since the player is not required to progress in a started quest, the player could choose to level grind between the various encounters with the demon in the quest. The result could be a final boss that is much easier to defeat than the first two bosses.
    • Subverted in "While Guthix Sleeps" and "Ritual of the Mahjarrat" quests. Despite being only Level 14 in the Temple of Ikov quest, Lucien becomes immensely powerful and obtains two god-weapons.
  • World of Warcraft:
    • Bosses tend to this, such that players will occasionally revisit particularly frustrating dungeons 20 or 30 levels later for the pleasure of curb stomping the boss that gave them so much trouble the time before, sometimes even single-handedly. Aversions to this are Heroic dungeons, where two versions exist, one for top level characters. Also the sorcerer Arugal, who appears as the boss of a 20th level dungeon, then is resurrected as a 70th level elite. Arugal's former residence Shadowfang Keep, while he's no longer present, also gets a heroic mode. This leads to a 65 level difference between the normal and Heroic mode. The similarly-leveled Dead Mines also get an 85th level version. Seeing as it's supposed to be a direct threat to Stormwind itself, this is appropriate.
    • Averted by bosses that appear again in a higher level dungeon, especially if they're moving from 5-man dungeon to raid. Anu'barak, Thorim, and all three Blood Princes multiply their hit points several times over by the time they show up as bosses.
    • The Naxxramas bosses go from Level 60 to Level 80 in Wrath of the Lich King (an expansion pack that focuses on the battle against the Scourge, which includes the residents of the dungeon), but in the 10-man versions, some of them have fewer hit points than their original 40-man counterparts. Ragnaros returned in Cataclysm at Level 85.
    • Kael'thas actually devolved a few levels, between his appearance in the endgame raid Tempest Keep and his coda as the end boss of five-man Magister's Terrance. Given that he was severely injured in Tempest Keep, and still has a giant chunk of crystal embedded in his chest, it's understandable.
    • The Apothecary trio from the "Love is in the Air" event did grow stronger with each expansion, but not proportional to the player characters. As of Battle for Azeroth, what was initially a tricky boss fight that required strict adherence to fight mechanics has become so easy that most party forgo a tank and healer and just burn them down. Notably, what used to be a mad rush to take down the first boss before the third one became active is now instead a waiting period between killing the first two and the third one activating.

    Puzzle Game 
  • Tetris Attack and Pokemon Puzzle League have a single-player campaign which consists of a series of levels with gradually-increasing speed. Halfway through both games, there's a special level where you essentially fight the final boss with a speed of about 45 (from the previous level's 20.) The thing is, if you keep playing through the game, the final level/boss has the same speed of 45, while the previous level's speed this time is 40. (Incidentally, you can beat the boss at the halfway point just as easily as at the end of the game — doing so just gives you a cutscene and puts you at the second half instead of ending the game.)
  • Mamono in Puyo Puyo. In his first appearance in Madou Monogatari I, he's the Final Boss for a kindergarten-age Arle. In Puyo Puyo 2, he's just a possible opponent for a teenaged Arle in Floor 5 alongside Witch, Suketoudara and Pakista. Mamono even starts crying after Arle realizes he's indeed not the Final Boss.

    Role-Playing Game 
  • Absinthia: Lilith was an endgame boss in previous games in the Knights of Ambrose series, but here, she's the very first boss of the game and can be defeated by a trio of novice fighters and their mentor. This is justified because she threw the fight to make Freya look like a heroine and she lost a lot of the angelic and demonic power she had in previous games. When the party fights her for real as the Final Boss, she's at least on par with the optional bosses in terms of stats.
  • Justified and played for laughs in Alluna and Brie. The second time you fight Eldoris, at the end of the game, she's just as strong as the first time, which was all the way at the beginning of the game, because she's been watching crappy romantic movies for six months instead of training while trapped in LiCastro Manor. This being Alluna and Brie, this ends up lampshaded several times after the fight.
  • Played for Laughs in Finnel Cosmosphere Level 4 (the real one) in Ar tonelico Qoga: Knell of Ar Ciel, where SHOGUN TATSUMI runs due to a Deus ex Machina after almost winning the first time you fight him, but he's pitifully weak when you face him the next time.
  • Barkley, Shut Up and Jam: Gaiden has this with Michael Jordan and Vinceborg; they both seem to be a little more powerful the second time you fight them, but your strength and numbers make both rematches fairly anti-climactic (especially Jordan). Plus, you fought both at the same time the first time, and separately the second.
  • In Baten Kaitos Origins, you fight Giacomo three times. The first time he's an infuriating Early-Bird Boss who can easily one-shot a party member with Thrashinggale and his second match he becomes a Flunky Boss with a new attack but is otherwise appropriately difficult. In his third however he's no stronger than the second match (only gaining buffing abilities) while you've probably gotten at least two or three levels and new magnus, turning the fight into an extremely satisfying ass-kicking with him on the ass-end. It was done intentionally, as his inability to keep up with Sagi's growing power is what drives him to become what he is in the sequel.
  • Zig-zaggedly justified in Bloodborne: The first time you play through the game, some of the toughest enemies you can encounter are NPC Hunters. Come New Game Plus, however, all enemies except for the Hunters will have gained a significant power boost. On one hand, this is justified because the NPC Hunters are created using the same character creation system as your own character, meaning there's an upper cap on how strong they can be, and a couple of the Hunters are maxed out already on your first playthrough... On the other hand, the Hunters who could receive level-ups to maintain their positions as challenging opponents still do not get any level ups... On the third hand, this is also justified as some Hunters actually are canonically weaker than others. Example 
  • Barubary in Breath of Fire II inverts this, but then again, the Final Boss Preview (or rather The Dragon preview) IS him just picking on a little kid in the prologue. Grown up and come back with a real sword, you stand a much better chance, though it's still possible to die.
  • Chrono Trigger:
    • The final boss's first form is a Boss Rush in which he mimics every boss fight from the entire game up to that point... without upgrading their stats. The first few go down in one hit, and most of the rest aren't much harder.
    • This also occurs in New Game Plus, where after running through the game a couple of times, Lavos can be defeated at the very beginning of the game with just Crono and Marle — or even Crono himself.
    • Magus is fought at the grand finale of the 600 AD subplot, and it's a grueling, drawn-out slugfest that takes three party members punching through an elaborate magic barrier. Later on, one of your party members can choose to duel him one-on-one, and his stats are exactly the same, and he lost his magic barrier and the powerful attacks that made him so hard due to being weakened by Lavos. In this case, however, it's less 'forgot to level grind' and more the fact that his plan for defeating the true Big Bad of the game is in ruins and he doesn't much care whether he lives or dies at this point.
    • Zig-Zagged by Spekkio, who "levels up" with your strongest character, but once you reach level 50, he won't level up again until level 99, which most players only reach for the sole purpose of fighting this boss in his ultimate form. At level 65, you have him completely outclassed. And before level 50, he only actually transforms at every 10th level. If you take advantage of this and fight him one level before he upgrades, he poses little threat.
  • The Avatar of Khaine in Dawn of War 2 is a nightmarishly difficult enemy, with abilities that will one-shot most of your squads, three hundred thousand health, and a crazy amount of support requiring Terminator armor, plasma cannons, and thirty to forty minutes of alternately beating on it and running away to defeat, combined with several orbital bombardments. When you run up against another Avatar in the Chaos Rising expansion, however, it's still got three hundred thousand health and the same abilities, despite the fact that your squads are six or eight levels higher, and can be defeated with conventional weapons. In fact, the only reason the Avatar in Chaos Rising isn't a Curb-Stomp Battle is that you don't have Terminator armor or Orbital Bombardment at that point in the game.
  • A recurrent feature in Baldur's Gate. In the first game, early hazardous enemies like ogres, spiders and ghouls quickly become mooks, while by the sequel even the once fearsome doppelgangers become cannon fodder. In the second game, things like vampires, mind flayers and beholders are increasingly painful and dangerous (while other monsters like umber hulks are at least annoying and disrupting), but by the time you hit the expansion, you will slice through them like a hot knife in butter.
    • Vampires are hilarious if you have a cleric. After the tough battles in Shadows of Amn, during Throne of Bhaal you can instakill them just by pressing the "turn undead" button if your cleric has leveled up enough.
    • And speaking of vampires... Bodhi. She's a difficult but doable encounter in Chapter 3, but the final battle with her in Chapter 6 comes after you gained tons of XP, many powerful magic items and even up to three allied factions joining you in the battle. Her in-game threats and provocations could get almost ridiculous if you have installed the expansion, since you can get to the Watcher's Keep as early as Chapter 2 and obtain humongous tons of experience and equipment that players aren't supposed to get until Throne of Bhaal (thus unbalancing player progression and battles). If that's the case, you can almost solo her dungeon with little effort during Chapter 3, and get to epic levels with high level abilities during the underdark, meaning that the final confrontation in Chapter 6 can be an instakill walking parade (against her minions) and an easy boss shutdown (against her).
    • Dragons can be spectacularly this with a little metagaming: hard and challenging the first time you meet them, but almost always with an option to avoid battle; quickly disposed off if you level up before returning and ultimately engaging them.
    • While indeed a difficult opponent in the first game, Sarevok can return as a shadow in the sequel for a quick confrontation, at the same level you left him... while you already surpassed him, with stronger gear, while he doesn't even have anymore his former allies assisting him.
    • Averted with Irenicus: he grows stronger every time you face him.
    • Averted too with random guards, but also subverted: while they grow stronger and with better equipment, they do at a slower pace than you. A single guard in Throne of Bhaal can solo the entire Flaming Fist headquarters in the first game, but by that time you can easily kill all the men-at-arms in Saradush or Amkethran, while in the early levels of Baldur's Gate the Fists could be tough opponents for your rookie party.
  • A rare unintentional example comes from Cthulhu Saves the World in the form of the Three Heroes of Goodly Justice. They were supposed to be fought on multiple occasions, as a Goldfish Poop Gang... that the developers forgot about, so in the final product, you fight them twice — once at the beginning of the game (where they serve as the first boss), and the second time near the end (where they're as strong as before).
  • Happens a few ways in Dragon Age: Origins. While enemies level up in scale with you, many of them don't gain any new abilities, while the party does. Those new abilities are often able to even out or overcome the advantages that some of the tougher early-game enemies have.
    • The first ogre you meet is a Wake-Up Call Boss that will kill you if you aren't prepared for it. By the endgame, three or four of them together don't pose nearly the threat that the first one did.
    • Also, the Revenant. The first one is, most likely, going to be the toughest one of all. The thing is powerful, tough to kill, and likes to pull ranged attackers to it. Each subsequent one is slightly weaker due to your Level Grind. While none of them are truly weak, the last one you're likely to encounter will hardly give you any trouble.
    • As far as individual characters go, Ser Cauthrien was an incredibly difficult encounter that you were meant to lose so that you could ultimately be captured. Fighting her before the Landsmeet, she's a medium difficulty boss that goes down with a minimum of fuss. Note that these can happen pretty close to each other, and in fact she's made physically weaker (and backed up by fewer mooks) in the second encounter.
  • This trope is inverted in Lost Odyssey, where a hero is the one that forgets to level. The first time the player controls Tolten he is about the same level as the main cast, and holds his own well enough when forced to fight. However, he does not become a regular party member for another disk, by which point the other's have leveled so much that Tolten seems to die to a stiff breeze and is no help at all in the first dozen or so battles. Luckily the leveling system allows him to gain levels quickly to catch up. This may actually have been intentional, as he is supposed to be a sheltered prince who has to learn to be strong.
  • Dragon Quest IX has a not-so-Quirky Miniboss Squad in the Triumgorate, and each member of the trio gets their own separate boss fight with plenty of hype leading up to it (except Goresby-Purrvis). And then, in the Realm of the Mighty, you have to fight them again...while they've apparently gained exactly zero levels in the meantime. Vaguely justified in that their pre-battle dialogue implies that they were very recently resurrected, but then again, given the power of the Big Bad behind them, you'd think they'd be made a lot stronger.
  • Happens as a result of a "feature" that is almost certainly a bug in The Elder Scrolls V: Skyrim. Unique NPCs don't "level up" with the player, being stuck at the level they were first spawned (unlike Oblivion or Fallout 3, where key NPCs would automatically level up to match the player). Two key NPCs, Ulfric Stormcloak and General Tullius, are spawned at the very beginning of the game. As a result, when you finally face one or the other of them at the end of Civil War questline, they're stuck at their minimum level and are easily dispatched by a mid-to-high level player. After several months, they finally patched this during the first DLC release. The engine now re-calculates the NPC's level each time they get loaded in a new cell.
  • Final Fantasy:
    • In the original Final Fantasy, the Light Warriors fight the four Elemental Fiends again. Lich, the weakest of the fiends, is not an example of this — he's learned to cast Flarenote . Marilithnote , however, is — she was the second of the four Fiends fought, and was first encountered by a party probably in their mid-teens, level wise, whereas in the final dungeon they're likely in the high 20s in level. To a lesser extent this applies to Kraken and Tiamat, but it's unlikely you'll have outlevelled them to the point that they're pushovers — only somewhat and slightly easier, respectively.
    • Final Fantasy VI: Kefka is an inversion of this trope. At the start of the game, he's a joke who bails from even the most basic blows Sabin can dish out. He does scale up in power very quickly due to his manipulation of the Espers the Empire controls to the point where he not only kills off the Anti-Villain and fubars the peace conference in Thamasa, but also overthrows his own boss, fubars the whole world, and rules over it like an Evil Overlord.
    • Final Fantasy VII: The Midgar Zolom is a Total Party Killer when you first run into it, being meant more as a Beef Gate than a boss proper. Fleeing from the battle or avoiding it altogether are the intended strategiesnote . Come back on Disc Two or Three and it's much less of a threat, to the point that if you come back after visiting the North Pole, you'll have a hard time acquiring its "Beta" Enemy Skill because by this point, your Cherry Tapping will One-Hit Kill the Zolom.
    • In Final Fantasy VIII, while enemies will level up with you, all the mandatory bosses have a level ceiling, that gradually increases throughout the game to 50. The optional bosses can still go all the way to level 100, though.
      • When you meet BGH251F2 for the first time with Selphie's team at the Galbadian Missile Base, it's one of the hardest bosses in the game yet. It has Beam Cannon, an attack that two of your party members (aka those without a GF junction that increases health) will likely be unable to survive, and once you destroy four of its turrets, the tank will begin spamming that attack every turn. Oh, and you're under a timer to finish it off as quickly as possible. To add to that, it's virtually impossible to actually deplete its full health (since the machine stops fighting once its' HP gets lower than 20% HP) and get a 20 AP reward unless you get really lucky with Selphie's Slot at just the right time. Then, a couple of hours later, you fight its' damaged version with Squall's team. Of course, by that point, you have gained a level or two, already got to know the machine's elemental weaknesses, likely have access to a very useful for this fight Leviathan GF, and maybe even a few Thundaga spells. BGH251F2, on the other hand... has exactly the same amount of HP but doesn't spam Beam Cannon and instead uses a much weaker attack most of the time (that can be protected against to reduce its damage further). The peak of Galbadian technology that was a formidable foe just a short while ago can now barely put up a fight.
    • Final Fantasy XIII has Barthandelus. His first form at the end of Disc 2 (Xbox 360 version) is one of the hardest bosses in any Final Fantasy story-wise, and his second form, which is fought at the end of Chapter 11, falls squarely under That One Boss. He returns as the first form of the final boss fight, where all but one of his attacks are laughably weak and he loses the ability to inflict status ailments. (Granted, the 'one' falls squarely under That One Attack, but it's still easy to recover from). Justified though by the fact that he wanted to die.
    • Caius Ballad in Final Fantasy XIII-2 remembered to grind, but got cocky about how much he needed. A low level party will need up to half an hour to beat his final form, but a high level party will only need three or four minutes. Unfortunately for the party, it was a case of Morton's Fork.
    • Zig-Zagged in Final Fantasy Tactics: While all story battles are at a set difficulty (instead of scaling with the party like random battles), recurring enemy Wiegraf steadily gets upgrades in gear and kickass ability each time the party faces him (culminating with transforming into Belias, one of the Lucavi).
  • Golden Sun:
    • Saturos and Menardi run into this pretty hard, since Isaac and company go from kids with magical powers to powerful spellcasters who happen to be kids. They're completely unbeatable in their first appearance, only beatable because of outside factors (and the fact that only one of them is there) in their second and then entirely beatable (although with difficulty) even after fusing into a two-headed dragon in their third. Saturos and Menardi stay at roughly the same level throughout the series (getting weakened or strengthened through outside forces, never their own), Felix and Jenna are just as wimpy (level-wise) at the start of The Lost Age as they are (well, Felix is implied to be a poor fighter, Jenna just has a low level cap when she's playable) at the beginning of Golden Sun even though they've been traveling with Saturos and Menardi, Alex has trouble wrapping his head around the concept that Isaac & co. could beat Saturos and Menardi, and Isaac & co., despite spending months at sea, obviously fighting random battles, don't gain a single Experience Point between the end of Golden Sun and when they join you in The Lost Age. Justified with Felix and Jenna in the first game, as the latter is a hostage for the vast majority of it and the former is directly stated by Saturos and Menardi to be kept out of fights during their travels specifically so he would never be able to become strong enough to be able to oppose them.
    • Subverted with Alex. He starts out as the series' most powerful character, then grinds hugely at the end of The Lost Age, and appears to have ground even more with the coming of Golden Sun: Dark Dawn, effortlessly OHKOing a main character.
    • Golden Sun: Dark Dawn has Blados and Chalis. The first time you battle them, at Luna Tower, they're appropriately challenging. The second time, some twenty-odd levels for you later, at Apollo Sanctum, Chalis has a new dagger... that is apparently just for looks, as neither one's stats or abilities have changed at all.
  • Inazuma Eleven 2, Aliea Academy's teams don't seem to level up that much while the heroes are all for Training from Hell and aces recruiting to get better, though Epsilon Kai subverts this by turning their eyes red.
  • Jack Move: The first time Noa fights Krall, it's a Hopeless Boss Fight where she downs Noa in one 5000-damage attack. This is exploited later on in the final battle where Krall has become an uploaded consciousness that uses Noa's memories to transform into various previous bosses. She gets tricked into turning into herself from that very same battle with the same stats apart from HP, and since Noa is now a lot stronger compared to then, Krall deals laughable amounts of damage and is easily beaten.
  • Kingdom Hearts: Xemnas features as a super boss in Kingdom Hearts I Final Mix, and is hands down the toughest fight in that game. By the end of Kingdom Hearts II, he's not even the toughest member of Organization XIII. Though he's the final boss and leader of the group, defector Roxas - who became a proper boss fight in II Final Mix - is considered by many to be much harder.
    • Done on a much larger level in Kingdom Hearts 3 where many bosses including Ansem Seeker of Darkness, Vanitas, Terra-Xehanort, Saix, Marluxia, Luxord, Xemnas and Young Master Xehanort are fought in groups. Averted in the DLC where each boss from the new Organization 13 are fought individually and are much tougher.
  • Knights of the Old Republic:
    • Darth Bandon from the first game is such a powerful figure in his first appearance, in the tutorial level, that you aren't even given a chance to fight him. He appears later on as a not-particularly-tough boss. Calo Nord as well, especially if you count his first appearance, effortlessly stomping three Rodians. And your party, if you fight him in the cantina.
    • The second game has the Twin Suns on Nar Shaddaa, who you have to fight with just Atton in the cantina first. They're tricky enough to become That One Boss unless you've made special preparations for them. When you face them again on the way out from Goto's Yacht, you have a full party, and most importantly, your incredibly strong main character, and they can be stomped without worry.
  • In The Legend of Dragoon, a little under halfway through the first disc Dart and Lavitz face an Elite Soldier of Sandora as a somewhat tricky boss fight. Come the end of disc one, you fight another and he's only a bit stronger than the average Mook due to how much more powerful your party is (that you have a full party as well helps).
  • Used interestingly in The Legend of Heroes: Trails of Cold Steel. The first time you fight <C>, he's Level 60 while you're around the low 40's, and it's a Hopeless Boss Fight. When you fight him for real two chapters later, your party will be around Lv 60 while he's only gained a couple of levels. He's now beatable, but he's still That One Boss.
    • Though played straight in the sequels when you fight the same character again. Not only is he now relatively easy, but Rean, the main character, now fights him alone and wins rather easily in story.
  • The Final Chapter of Live A Live has the True Final Boss pitting the individual characters in rematches against the final bosses from their respective chapters. However, if you have rotated the group throughout the chapter to level all of them up, as well as getting the ultimate weapon upgrades for each character, this time, the bosses aren't nearly as powerful.
  • Lufia II: Rise of the Sinistrals combines this with Cutscene Power to the Max for the first and second fights with Gades. Unless you level grind for the first battle, it's a Hopeless Boss Fight. For the second battle, you're actually at a disadvantage: Magic Knight Maxim is your only healer, with the other two party members only about to use one strategy.
  • Morag in Magi-Nation is fought in an Hopeless Boss Fight. By the time you fight him for real, he's...well, he still puts up a fight, but isn't nearly as powerful as the first time he almost kills Tony Jones.
  • The Collector ship effortlessly pwns the Normandy in the opening scene of Mass Effect 2. Make the right investments, talk to the right people, and do the right research through the game and that same ship gets pretty effortlessly obliterated by the new Normandy.
  • In Mega Man Battle Network 3: White and Blue, the first time you fight Bass, he is a Hopeless Boss Fight protected by an impenetrable aura. The second time you fight him right before the Final Boss, his Aura can be broken through, and he's got a simplistic attack pattern compared to the other bosses you've faced up to this point. Then you face him as a Superboss in the postgame, and get utterly destroyed by him.
  • In the first Megaman Star Force game, when Gemini Spark begins the Boss Rush leading up to The Very Definitely Final Dungeon, he is still in his normal form, unlike his fellow FM-ians, who have to be fought in their upgraded "EX" forms.
  • Parodied in Mother 3, where the mole cricket you fought in the very first battle challenges you to a rematch... in the second to last chapter of the game. Interestingly enough, according to him, he has trained the whole game for that match; but he's, well, a bug. A normal-sized bug. The only noticeable boost he shows is in speed, so he can show you how much of a pushover he is before going down.
  • In Paper Mario: The Thousand-Year Door:
    • Doopliss has the same health and attack power when you fight him alongside the other Shadow Sirens in Chapter 8 that he does when you face him alone at the end of Chapter 4 (both the fake end and the real end). Meanwhile, Beldam and Marilyn have become stronger since the last time you fought them, as has Bowser.
    • Rawk Hawk never grows any stronger no matter when or how many times you fight him. Especially jarring, since he explicitly says he's been training like crazy, and even sends Mario an e-mail asking for a rematch.
  • Persona:
    • Strega from Persona 3 aren't a huge threat the first time you fight them, but they don't seem to have become stronger at all when you fight them again, months later.
    • Justified for Tohru Adachi from Persona 4. At the start of the game, even thought he doesn’t fight the protagonists, he’s stronger than they are. But by the end, when you fight him, you are more powerful than him. This makes sense in the story because unlike the protagonists, who have been spending a lot of time in the TV world and fighting shadows, Adachi hasn’t really gone into the TV or used his persona to fight anything up until that point, so he’s not as strong as you are, nor does he have battle experience like the Investigation Team does, so of course he’s going to lose.
  • Exaggerated in Phantasy Star IV with Zio, who is completely unbeatable the first time the party fights him due to his Magic Barrier and One-Hit Kill Black Wave attack. The second time the party fights him they have the Psyco Wand, which nullifies said Magic Barrier / One-Hit Kill Black Wave and reduces Zio's stats to the point where he can actually be beaten.
  • This is the intrinsic problem with Gym Leaders in Pokémon. The player has the ability to level grind after being beaten once, then come back and stomp the Leaders flat the next time around; the Leader has to stand there and take it. The story in Pokémon Black 2 and White 2 reveals this is actually the case in-universe; the first Gym Leader is one of the rivals from Pokémon Black and White, and he complains about not being able to use his old team, whereupon it's pointed out that a Gym Leader's role is to test incoming Trainers, not perpetually overpower them.
    • Giovanni in Pokémon Red and Blue seems to be an example of this trope. The first time you fight him, his Kangaskhan will be ripping through your party left and right. It's somewhat easier the second time you fight him at Silph Co, as your Pokemon will have started evolving and learning better moves, whereas before Kangaskhan was using moves that were really strong for that point of the game. When you fight Giovanni in Viridian Gym, it is painfully easy. All of Giovanni's Pokemon are of the Ground type, with many being Rock types as well. That is the very first type you learned how to exploit back in Brock's Gym, and to make matters worse, you just got done facing a Fire Gym, so you're almost certain to have a decent Water type on you who can rip through Giovanni's team.
    • Averted in Pokémon HeartGold and SoulSilver, where the Elite Four will level up and change their team lineups after getting all 16 badges.
    • A variation of this occurs in Pokémon XD: Gale of Darkness. Near the beginning of the game, Ardos is seen using a level 44 Alakazam to wipe the floor with Zook's level 28 Zangoose. When you actually fight Ardos near the end of the game, that Alakazam is still level 44.
    • This becomes especially problematic in Pokémon Platinum; after the Elite Four, the player can explore the island where Battle Tower is — north of the tower is a hangout for Gym Leaders and other elite trainers. At first, a player who doesn't level grind will find the rematches challenging, but once their team starts growing past the Gym Leaders, said leaders will no longer be a challenge — they're stuck in the Level 60's.
    • The Rival stands outside this building, where you can fight him on the weekends. His levels are also a little tough at first, but you quickly surpass him. There is a way to make him increase his levels, but you have to beat the Elite Four twenty times.
    • Averted in Pokémon Black and White onward, as the Elite Four grow more powerful after the first time you complete it. In addition, their first teams will have 4 members while their rematch teams will have 6.
    • However, Pokémon Black 2 and White 2 has the Pokémon Breeders who challenge you every time you enter their area. Not so bad the first time, but after you finish the game, they still challenge you, even though they're at level 20 or whatever and you're nearing level 100. Cue Curb-Stomp Battle.
    • Averted in the Lets Go games as well, to a point. After completing the game, you are able to re-challenge the gym leaders, and they all present a full team of high level Pokemon. It is implied that this is their real battle team. While still a mono-type team, even Brock and Misty can put up a serious challenge if you did not expect it.
    • Averted by Sordward and Shielbert in Pokémon Sword and Shield. You encounter them first at the beginning of the post-game storyline, where they battle you and your rival for possession of the Rusted Sword and Rusted Shield. You fight them again shortly afterward at the Pokémon Lab, this time with higher level teams. When you fight them again even later, they've leveled up again.
  • Skies of Arcadia: A problem in the Director's Cut Nintendo GameCube version: The boss villains from the original game don't level with the players. The optional bosses do level, though.
    • There's also the hilarious Curb-Stomp Battle when you fight Baltor for the second time. The first time around, his pirate ship is a legitimate challenge. The second time, he's got exactly the same ship. You've got the Delphinus and her Moon Stone Cannon.
    • Random ship battles with Black Pirates in the overworld are genuinely hilarious once you get the Delphinus for a reason. They're a threat at first, when you have the Little Jack (a small wooden ship). Later on, they still have the same old wooden pirate ships, while you have a freaking metal destroyer. It's the equivalent of attacking a WWII destroyer with an 18th century sailing ship, and the results are as expected. You basically one-shot them with the weak attacks, no need to use the Moon Stone Cannon. Unless it amuses you, of course.
  • Lampshaded in Suikoden Tierkreis. After beating the crap out of Conon (who had been half of a Hopeless Boss Fight several times by this point), the hero wonders why he's so much weaker all of a sudden. Liu tells him he isn't, he just hasn't been getting any stronger, while they have.
  • The Four Horsemen in Summoner. You can run across them early in the game in random encounters, but you can't kill them. All you can do is try to survive and get their hitpoints down until they leave for some reason, and that's hella hard. When you reach them in the main storyline, much later, then you can kill them.
  • In Tales of Symphonia, you fight the Big Bad Yggdrasill four times. The first time, he obliterates you in seconds. The second time you fight him, he has the same stats and you can hold your own against him until the battle is interrupted. The third time, he's actually weaker and doesn't spam Outburst. Then again, you're not supposed to win against him the first two times... He does get stronger when facing you the last time, as the Final Boss.
  • Three the Hard Way has Benson and Mauldin, a pair of enemies who were first encountered as a Hopeless Boss Fight, and would have killed the protagonist, Vance, if not for outside help. Depending on which path the player chooses, the heroes may find the opportunity to fight the villainous pair again, but this time they could defeat the two quite easily. This is lampshaded by Benson after they are beaten, as he demanded to know how the heroes suddenly became much stronger than they are.
  • In Tin Star (Choice of Games), this is averted by Caraway, Dan Schmidt and Ben Carson. Though they're not villainous, you can kill each of your three possible companions on your first meeting when their skills aren't all that exceptional. You can also anger them later and have showdowns with them near the end, in which case they will be the deadliest opponents in the game.
  • The old PC game, Winged Warrior, has The Dragon named the Nova Knight who serves as a Hopeless Boss Fight halfway into the game — his level is leagues ahead of your titular hero's, all your landed hits on him are mere Scratch Damage, and he will deliver a Curb-Stomp Battle on you when you first battled him, forcing you to retreat at which point he taunts you with a We Will Meet Again threat. You then spend the rest of the game levelling up, until you can defeat elemental dragons and all sorts of Elite Mooks with ease, as well as learning a powerful new spell, the Void, which deals a One-Hit Kill on most enemies... then you face the Nova Knight again, in the final stage. Behold, the Nova Knight's stat are exactly the same as he was back when you first battled him. And you can practically wipe the floor with him this time using the Void spell.
  • Letho from The Witcher 2: Assassins of Kings. When Geralt first faces him in combat, Letho is a very difficult boss fight that requires you, the player, to throw everything you have at him. Even after defeating him, Letho uses Cutscene Power to the Max to turn the tide, with Geralt only surviving because Letho spares his life. During the second confrontation with Letho at the end of the game, Geralt collected all kinds of fancy new weapons and powers, while Letho largely stayed the same, turning this battle into a cakewalk.
  • Ra-Sep-Re-Tep in Wizardry: Crusaders of the Dark Savant. He's the boss of the starter dungeon and reasonably challenging for a fledgling party. He then turns up again much, much later in the Chamber of Gorrors. The other monsters here are extremely challenging Optional Bosses but Ra-Sep is totally unchanged and at this point you'll probably kill him in one hit.
  • Early in The World Ends with You, Uzuki "can erase you in a second." Once you've reached level 30, she's much less intimidating. The same goes for Kitaniji, who's amazed at how much power you've gained.

    Simulation Game 
  • Princess Maker 2 has characters who are ostensibly supposed to be 'rivals' to your progeny. However, they remain at exactly the same level while your little princess grows strong enough to defeat the God of War.

    Turn-Based Strategy 
  • Often in Sid Meier's Civilization series of games, the human player will find that although the AI civs have advanced technologically at similar (or even greater) pace than the player did, they've failed to upgrade or replace a lot of obsolete units, even defensive ones (sometimes a human player may forget to as well). So once a player polishes off a couple of updated defensive units in an enemy city (or advances past better-defended outer cities), they find themselves fighting... pikemen or spearmen with tanks. Seemed to happen more in earlier editions of the game, by III or IV the AI was a bit better at upgrading. (And if in Civ II they had the Leonardo's Workshop wonder, such upgrades would be automatic.)
  • Very, very common in many of Nippon Ichi's games such as the Disgaea series, due to the insanely high levels you can reach — the plotline fights are scaled on the assumption that you'll mostly only gain levels from plotline fights, and not go gallivanting off to the Dark World or Cave of Ordeals or Land of Carnage.
    • Even fights where you're supposed to be curbstomped by the overwhelmingly powerful boss (Beauty Queen Etna, anyone?) can be won through higher levels and good equipment, although that sometimes lead to a Nonstandard Game Over due to plot derailment. (Defeated Feinne too early? Here comes Asagi to ruin everything and forcing you to start all over again.)
    • Downplayed in Phantom Brave. Your steal resist is based on your level and class title. If the boss begins the battle unarmed and all you've done is powergrind your WEAPON and not your character...he'll just steal it and slap you with it for a One-Hit KO without batting an eye. Due to their high steal rate Funguys and Bottlemails eventually become among the worst enemies for high-level characters to face down with weapons. So essentially they didn't need to level because you were nice enough to provide them with an alternative means to kill you.
    • The easiest way to grind experience and Mana is to create high-level dungeons and attach a weak title to it so that the enemies inside have reduced stats...but they will still retain their high level and steal rate, meaning you're in for a beating if you can't kill all before they get a turn.
    • A handwave as well: when you beat Optional Boss Laharl for the first time, he rounds up his minions telling them to upgrade his weapons in the Item World.
  • Final Fantasy Tactics:
    • Some battles have enemies that level. All random battles have the enemies level with you, and some story battles (usually the ones that feature monsters and no real story components) do as well. So if you've overleveled, you'll end up fighting some incredible powerful meteor-summoning chickens, to thrashing the next boss powered by dark magics with a wave of your hand.
    • Interestingly, the player can suffer from overleveling, as some monsters are very strong, and while the player may gain some levels, they don't get the better equipment they're expected to get at those levels and facing those enemies. Rarely a significant problem as it's not a significant boost most of the time. However, as the high level gear carried by these scaling opponents can be stolen, this barrier can also be overcome, and provide the player a massive advantage beyond the simply higher stats from leveling up.
  • Fire Emblem:
    • In Fire Emblem: The Sacred Stones, this trope was invoked on recurring bosses... in the English version. Their stats were slightly higher when refought in the Japanse version. Valter, for example, promptly kicks Seth's ass during the Prologue (it was a cutscene but the stats were there). Come Scorched Sand and he reappears, not having changed a bit since then, and your party has had plenty of opportunity to level grind in the Tower of Valni.
    • A subversion in Awakening: the boss of the Premonition appears early on in the actual story weaker than in the first battle, but that's justified since the Premonition is a dream of the future. Come Chapter 23, and the boss appears exactly the same as it did in the Premonition, meaning you should be able to easily curbstomp it...until you do and it turns out to have been hiding its true power, resulting in a rematch where the boss has stats actually befitting a boss this late in the game.
    • Also subverted in Fire Emblem: Three Houses — the Death Knight will be a bit stronger every time he appears on a map, though eventually your units will actually be strong enough to kill him given the correct weapons.
  • The Dread Lords of Galactic Civilizations II have incredibly powerful warships from the very beginning of the game that will eat anything an early-to-mid game player can throw at them for breakfast. As the game progresses however not only do their warship designs fail to improve to counter your own, but they also rarely group them into fleets to give them a strength in numbers. Eventually, if you can survive their attacks long enough to research superior weaponry and logistics to field not only powerful warships but also group them in bigger fleets than they do, you can gang up on their mostly solitary vessels and destroy them with only light casualties, causing them to degrade from an Invincible Villain to a Mini-Boss.
  • Tactics Ogre as well as Knight of Lodis have this show up. To elaborate, the games use a system in which the enemies will be around your characters' levels (Specifically, the leader's level). However, after a certain point in time, the enemies in story battles stop leveling up, meaning you can go in and slaughter the final enemies at level 50, when they only cap out around the 30s.
  • Enemies in XCOM: Enemy Unknown don't improve throughout the campaign, though they do get replaced with progressively tougher enemies... Most of the times.
    • The Thin Men are able to put on a decent fight when they first appear (Able to jump atop a building In a Single Bound and having a decent Aim stat as well as decent damage and a poison spit), but when they appear during Council Missions late game, even a team of Rookies with Light Plasma Rifles (or spare laser weapons) and Ghost/Titan Armor, late-game Foundry Upgrades, and possibly One-Hit Kill Psychic Powers will completely steamroll over them. Assuming you didn't purchase the New Guy upgrade from the Officer Training School which starts every new soldier with a promotion (and thus a special ability).
    • Exalt in Enemy Within are even worse. They are basically squaddies, only with worse stats and starting gear (they do are more numerous though). The Elites who appear later are just crappier version of corporals with Laser tier weapons... And stay there. Do the math.
  • Toyed with in XCOM 2. ADVENT didn't rest on its laurels in the twenty years since Earth fell, continuing to genetically modify their troops to fit the situation. Oddly enough, the basic troops that are used to enforce the alien rule over Earth use magnetic guns, which were a step back from the plasma-based weapons they used in Enemy Unknown. When XCOM gets going again, ADVENT does bring out upgraded versions of the basic humanoid mooks and bigger and badder enemies for you to face in something of a Mid-Season Upgrade, but then get outpaced again when your troops get their weapons and armor properly upgraded and get some experience under their belts.

    Stealth-Based Game 
  • Metal Gear has some occasional examples.
    • A humorous example in Metal Gear Solid 4: Guns of the Patriots: Psycho Mantis's spirit returns during the lead-up to the climax, and once again, he tries to read the player's mind and move their controller. Unfortunately, there's no memory card this time around, and the controller only moves if the player is using a specific kind. Mantis acknowledges that the player's skills — excuse me, hardware — have improved.
    • Metal Gear Rising: Revengeance has a few examples.
      • The first is Metal Gear RAY; though this is a twice-subverted example. It's been significantly upgraded from the versions that Raiden battled in Metal Gear Solid 2: Sons of Liberty, and it's far more intelligent and puts up more of a fight than those in Sons of Liberty (which were implied to be limited by the fact that GW was controlling them), but Raiden still devastates it with ease — with only a sword, thanks to becoming an absurdly powerful cyborg.
      • Jetstream Sam is fought shortly afterwards, and he curb-stomps Raiden with relative ease. Raiden battles him near the climax of the game after he has received a more powerful cyborg body and returned to sinking into his Superpowered Evil Side, and while Sam still puts up a hell of a fight, the battle is far more even.

Non-video game examples:

    Anime and Manga 
  • Bleach has an aversion with Grand Fisher, who is barely defeated by Ichigo early in the series. He comes back, explicitly points out how he did remember to level grind, only to be Killed Off for Real by Isshin Kurosaki, a former Captain in a Single-Stroke Battle.
    • Gillians. The first one introduced is treated as an Eldritch Abomination and considered by Rukia to be an impossible foe to defeat. Even injuring it enough to make it retreat nearly killed Ichigo. The next time they're fought, Gillians are treated as an opportunity for the Shinigami to show off their powers as they slaughter them by the dozen with ease.
  • Played with in the final episode of Bubblegum Crisis. A Mad Scientist tries to prove himself by destroying the Knight Sabers. So he creates a team of test Boomers to fight them and obtain their combat data for the real fight to come. Unfortunately for him, right after that battle, the Knight Sabers upgraded their hard suits...
  • Every monster from Claymore suffers from this. Justified by the fact that while the heroic Half-Human Hybrid abilities increase with time and training, the full monsters are at the top of their power and thus unable to improve. One notable example is when monsters of the same power level are met before and after a long Level Grind sequence: the first was narrowly defeated after a long battle which required sacrifice, technique, and luck; while the second one was defeated very easily.
  • Digimon:
    • Most of the Big Bads in Digimon Adventure require someone getting a new form that can beat them. The Dark Masters, however, didn't. In their first appearance, they take turns beating the stuffing out of the Digidestined's Digimon, Piedmon defeating both their Megas with no effort at all. Well, the Digidestined's Digimon don't get new forms, so they get more experienced and stronger with the ones that they do have. They beat MetalSeadramon and Machinedramon by wisely using WarGreymon's Dramon Destroyers, which are super effective on Dramon-type Digimon. Puppetmon is downed in one hit from MetalGarurumon, but Piedmon gets it the worst. Even though MagnaAngemon played a big role in his defeat, the same two Mega Digimon he effortlessly beat down back him into a corner and force him to pull out his most underhanded trick. Even without them, the Ultimates in the Digidestined's arsenal still manage to put up a good fight against him and once his trick is no longer useful, he gets his butt kicked. He saved himself for last but didn't bother getting stronger, so the Digidestined were able to catch up.
    • In Episode 2 of Digimon Adventure, Shellmon is defeated when Agumon digivolves to Greymon for the first time as the rookies aren't able to land a scratch on him. Come Episode 41, and three Rookies manage to curb-stomp Shellmon in seconds flat. This trope is even lampshaded by the Digi-destined to the Digimon.
    • Subverted in Episodes 40-49. In the former episode, "Meet the Dark Masters", Angemon takes two blasts from Machinedramon who comes out of nowhere and the impact is damaging enough to revert him back to rookie form Patamon. In Episode 49, he still gets outmatched by Machinedramon like the other Digimon before Wargreymon finally destroys him, but he is able to take two blasts at a faster firing rate without being de-digivolved. Being a champion, two whole ranks below Machinedramon, maybe this example isn't so mild.
    • In Digimon Frontier, the Royal Knights got hit by this hard. When they first fight EmperorGreymon and MagnaGarurumon, they beat them in a Curb-Stomp Battle. Subsequent battles can best be described as the kids losing less and less humiliatingly. In "To Make the World Go Away", they are evenly matched against the Royal Knights, and Lucemon needs to intervene to defeat them. In the very next episode, they curb-stomp the Royal Knights. Each fight made EmperorGreymon and MagnaGarurumon more skilled, but the Royal Knights didn't learn anything new.
  • Dragon Ball:
    • The Otherworld Tournament Saga in Dragon Ball Z. Almost every foe Goku had faced caused a riot in Hell. Goku and Picco... er, Pikkon go and beat their asses (Frieza and Cell are actually a threat at this point, but much less than they were when they were Big Bads).
    • Justified in-universe during the Android Saga, and the reason for The Big Bad Shuffle that took place in those arcs. Dr. Gero, when building the Androids, explicitly did plan for Goku's strength growing in the interim, and used a surveillance bug to observe his battles and calculate his androids' strength accordingly (Android 19 is able to defeat Yamcha even after Yamcha had trained with King Kai and spent a few years preparing for the androids). But for all his planning, he didn't follow the heroes to Namek, and so remained ignorant of several important power-ups first introduced there, such as the Super Saiyan transformation and the Namekian Fusion Dance. This means that when they do appear, Androids 19 and 20 (i.e. himself) are reduced to joke battles and he's forced to rely on two earlier models, who while far more powerful are also uncontrollable and have a grudge against him.
    • In Dragon Ball, Tao Pai Pai went from possibly the strongest human fighter on Earth and the first opponent to hand Goku a solid defeat to a below-average enemy only able to defeat the weakest of the supporting cast before being beaten senseless by a mid-level supporting cast member in the Tournament Arc at the end of the series. When he appears again in Dragon Ball Z (albeit only in the anime), Goku is so out of Tao's league that he's basically a joke villain who spends the episode engaged in wacky hijinks trying (hilariously unsuccessfully) to outsmart Goku. When Tao realizes Gohan is Goku's son (after using his signature move which didn't harm Gohan), he quickly flees.
    • Pilaf. This little guy and his halfwit minions first appeared when the series was more gag-oriented. They would appear again when the series began to focus more on the action, trying to steal Dragon Balls from Goku, right after he had become strong enough to defeat an army of terrorists single-handedly. To say the battle was one-sided would be a bit of an understatement. In fact, they themselves invoke Cerebus Syndrome by releasing Demon King Piccolo, who was the incarnation of Kami's cast-off evil.
    • Cui, Dodoria, and Zarbon are all part of Frieza's army, and mostly take it easy as they conquered planets. The few times they did get into fights, all of them were against vastly inferior competition. All three were known to have equal or higher power readings than Vegeta before his battle on Earth. One by one, Vegeta manages to pick off Frieza's men, noting that his powers have gotten stronger while Frieza's men have been relaxing around him.
    • Frieza is an interesting example in that old filler material and Non Serial Movies take a completely different direction compared to newer material from Dragon Ball's modern revival. In the original Manga, Frieza made one appearance getting killed by Trunks before he could power up, in order to show the latter's Combat Pragmatist nature.
      • Taking into account all of Z, GT, and the movies, Frieza returns and gets curb-stomped immediately no less than five times; once in the aforementioned battle against Trunks and four times after his death. After being killed by Trunks (he did get a power boost from his Cyborg implants, just not nearly enough), in the anime he terrorizes Hell and gets wrecked by Pikkon in a couple of hits. He gets back to the living world in the movies Fusion Reborn and Plan to Eradicate the Super Saiyans, but gets beaten up by the end of each movie. Perhaps his most embarrassing reappearance was in GT, where he gets beaten by an ice machine.
      • Modern Dragon Ball media by comparison goes into the opposite direction, and instead portrays Frieza as one of the few who can and does train to get strong enough to keep up with the Saiyans. The trope is averted for the most part in Dragon Ball Z: Resurrection 'F' (and Dragon Ball Super's adaptation), whereupon revival, Frieza (who in fact never trained before because he didn't have the patience and was born strong enough to conquer the universe anyway) trains for four months and gets a Golden Super Mode on par with Super Saiyan Blue Goku. Unfortunately for Frieza, it ultimately ends up being a case of History Repeats: while he did train hard to beat Goku, once he attained his new form, he made a bee-line for Earth to put it to use without first working to throttle its insane energy output. This is the exact same flaw that Frieza's "100% power" form had when Goku defeated him for the first time. While he's able to go toe-to-toe with Goku for a while and even downright dominate him in the anime version, it's not long before using this new super form leaves him exhausted, just like when he tried to use his full power back on Namek. Come Super's Universe Survival arc, though, and Frieza meditated while in Hell and managed to solve that issue by the time he's revived for the Tournament of Power. The manga later on has him discover a planet with a Hyperbolic Time Chamber, which he gleefully abuses to train for a decade and outclass everyone when he gets back- including two guys that had used Dragon Balls to explicitly wish to be the strongest in the universe, as well as beating Goku and Vegeta at the same time with a single hit- after an entire arc of getting stronger.
    • Inverted with Cell. When he first appears, Cell drains humans of their life force by sucking every last bit of their body through his stinger. This allows him to receive nourishment and to increase his battle power. He starts off being slightly weaker than Piccolo (after he fused with Kami) and Android 17. After absorbing thousands of humans, he becomes more powerful than both Piccolo's and 17's combined attacks and beats them senseless. He later achieves his main goal of absorbing the two androids and makes a massive jump each time in power. He also possesses the Saiyan's power to recover from near-death and come back stronger, though he is permanently defeated shortly after displaying this ability.
      • Played straight with Future Cell, who is just as strong as his past version... at that point, meaning that he's no match for the new, powered up Trunks.
    • Defied with Hit, a renowned assassin whose biggest strength is that he does level-grind like crazy. During his tournament fight with Goku, he levels his time skip up to more than double its original limit mid-fight, and every appearance since then he's showcased a new power that he didn't have before, like using the time he skips to turn intangible.
    • Painfully apparent in Dragon Ball GT when the old villains escape from Hell. Vegeta defeats Nappa without even trying, and Goku beats Frieza and Cell effortlessly in spite of the trap they set for him.
  • Fairy Tail:
    • Downplayed in the anime by Erigor, the Arc Villain of the Lullaby arc, and the first enemy Natsu fought in the manga he just couldn't blast away with sheer power and determination. While he dropped off the face of the Earth in the manga, he returns in the anime adaptation of the Nirvana arc as part of the many dark wizards in the guilds under the control of the Oracion Seis, eager for a shot at revenge against Natsu and mentioning explicitly that he did grind in preparation for this fight. Unfortunately for him, Natsu has level-grinded a hell of a lot more by this point and blows him away after a short battle. Averted in a Filler arc set after the Time Skip, however, as he's expanded his magical expertise and is now a member of the Neo-Oracion Seis and a clear match for the likes of Wendy and Bickslow.
    • Zig-zagged and subverted with Franmalth, who brags that his most powerful form is the soul of Master Hades, the Arc Villain of the Sirius Island arc, and an enemy so powerful it required five of Fairy Tail's strongest fighters and the fortuitous destruction of his Soul Jar to finally take him down. Since Natsu has already obtained his Second Origin, he figures taking someone with the exact power of Hades will be a cakewalk all by himself. Unfortunately for him, he's still no match for the likes of Hades in his prime, and with no Soul Jar for the villain to rely on this time, it goes back down to quick-thinking and the exploitation of Franmalth's weaknesses that Hades himself never had.
    • Bluenote Stinger appears during the Sirius Island arc as The Dragon to Master Hades of Grimoire Heart. He's a Gravity Master so powerful that Natsu and most of the other Fairy Tail wizards literally can't stand up to him, leaving Gildarts the only one capable of fighting him at the moment. Eight years later, Bluenote returns as the leader of his own guild. Natsu, having gone through the Second Origin power-up and a year of training, not only No Sells Bluenote's gravity-crushing power just like Gildarts did but casually takes out Bluenote with one huge fire blast to show just how much stronger he's become.
  • Played with a few times in Fist of the North Star. Quite often, villains do level-grinding, just not nearly enough to matter.
    • Shin has very explicitly not become any stronger between the two fights he had with Kenshiro, leading to his defeat in the rematch. It's later implied that he didn't want to become stronger, as he knew it wouldn't be nearly enough to take on Raoh when he came calling. Instead, Shin was just trying to have Ken become strong enough to protect Julia from any threat.
    • Jagi believed that a younger brother could never defeat an older one, so you'd expect this. Except he's still a Crazy-Prepared Hokuto Shinken practitioner and Kenshiro has already defeated him once. For their rematch, Jagi shows up knowing Nanto Seiken's techniques to compliment the ones he learned with his brothers, along with packing hidden guns (not that guns really matter against the likes of Kenshiro, who is so tough that he may as well be Immune to Bullets). All of this allows Jagi to go from helpless against pre-Shin Kenshiro to capable of... scratching Ken. A massive increase in strength, just not nearly enough to beat Kenshiro.
    • Shuu (who's not really a villain, he was just acting like one) not only didn't become stronger in the years between his two battles with Kenshiro but actually became weaker due to exchanging his sight for the right to spare Kenshiro.
    • Raoh didn't become stronger between his first and second fight with Kenshiro. However, Raoh had a lot on his plate. He spent most of the time between those two fights time recuperating from the wounds he suffered in that fight and his first battle with Toki, and had to restore his authority over his domain, then deal with the armies of the Last General of Nanto as soon as he had healed. It's usually averted, as Raoh himself declared he had grown a lot in the years between Ryuuken's death and meeting his brothers again; Kenshiro and Toki just took his growth for granted.
  • In Frieren: Beyond Journey's End, eighty years ago the demon Qual was so powerful he could only be sealed away rather than killed due to his creation of Zoltraak, a spell capable of piercing through all magical defenses. When Frieren returns as his seal is about to give out she deliberately lets it so she can use him as a training exercise for her apprentice. Qual is largely a victim of his own success, as Zoltraak was so effective it was thoroughly analyzed and adopted as the standard offensive spell, while more mana-intensive shields able to block it likewise because the default defense, and being sealed away while his invention revolutionized battle magic left him hopeless outdated.
  • Gundam:
    • Played with in Mobile Suit Zeta Gundam. as The Rival Jerid Messa tries (with increasing desperation) to level grind, and in fact does improve markedly over time, yet no matter how he improves or what Super Prototype the Titans gives him he's always a step behind The Hero Kamille. This is justified by Kamille being one of the most powerful Newtypes of the Universal Century, while Jerid is at best a low-level Newtype.
    • Inverted and discussed towards the end of Mobile Suit Gundam: Char's Counterattack, where it is revealed that Char deliberately forwarded his organization's Psycoframe technology to Anaheim so that Amuro would obtain it and be able to build a Mobile Suit that could fight on even ground with his Sazabi. But while the Nu Gundam and the Sazabi are equals technology-wise, the same cannot be said for Amuro and Char's respective skill as pilots, leading to a brutal No-Holds-Barred Beatdown from the former to the latter.
    • Ribbons Almark from Mobile Suit Gundam 00 deftly reveals himself to be The Man Behind the Man and betrays the Big Bad Wannabe to take the Big Bad spot, and immediately becomes a Knight of Cerebus due to his seemingly preternatural ability to predict everything before it happens. As it turns out, Ribbons is actually a Smug Snake who is cheating by using the supercomputer Veda to predict world events, and once the heroes realize this and start adjusting their battle plans beyond Veda's ability to predict Ribbons starts getting very nasty very quickly. It doesn't help him.
  • Kagura from Inuyasha nearly kills the eponymous character in her first two fights, but in the 3rd he's got a new ability that gets around her keeping him from using his best attacks, so he stomps her. Just about every other recurring villain in the series, however, also gets stronger as the series goes on, depending on whether they survive long enough for Inuyasha to get a new upgrade for the Tessaiga.
  • JoJo's Bizarre Adventure: Diavolo is arguably the only main villain in the series to progress as far as he has without the need for the sudden last-minute Power-Up, the signature of Araki himself. King Crimson was just as powerful and had all the same abilities at the climax of the final battle as when it was first introduced. Not that it matters, since his Rank A Strength and incredible speed, along with his ability to view the future and erase it, make him one of the most powerful villains in the series. Considering his motivation is actually getting that Power-Up MacGuffin for King Crimson, it's easy to say that if he got it he would have become so powerful absolutely nobody would have been able to defeat him.
  • Many of the opponents Kenichi faces off in Kenichi: The Mightiest Disciple often suffer from this. They are usually really good at their martial arts style, and will probably give Kenichi a beating the first time around. However, due to his Training from Hell he receives from various martial arts masters, he becomes a Combat Pragmatist and gets pretty good at defending himself. In one fight, when fighting against Takeda the Puncher, Kenichi focuses on his legs, which is a boxer's weakness and helps him to get the upper hand in the fight. Since he's not a villain, however, Kenichi will usually win them over with a speech or by giving them help (in Takeda's case, taking him to Master Akisame, and having him fix his crippled left arm, which allowed Takeda to take up boxing again), and many of them help him in later fights.
  • My Hero Academia:
    • Defied by the League of Villains, especially their leader Shigaraki Tomura. Just like Deku and the Hero Class Students grow stronger and more determined with each new trial they face on the road to becoming Heroes, Shigaraki and his recruits grow more powerful and dangerous as they advance towards becoming the world's greatest Villains. The Meta Liberation Army Arc showcases their growing powers and Character Development, with several members unlocking new aspects to their Quirks.
    • In the Dark Hero arc, Izuku comes face to face with the villain Muscular again. When they first fought during the Training Camp Arc, Muscular easily overpowered Deku and forced him to go beyond his normal limits to win, and only then by the skin of his teeth. Now, Deku not only has greater control of One For All, but he also has access to several of the Quirks of previous users and nearly a year's worth of additional training while Muscular has spent most of that time in jail. As a result, Deku easily flattens the villain in one manga chapter/anime episode.
  • Most recurring villains in Naruto play this straight, stomping the cast in their first battle, but losing as the heroes become stronger. Spectacularly averted though, by Kabuto, Orochimaru's Bastard Understudy. When he first appears, he's a Jonin-level threat who could probably give Kakashi a decent fight. But after incorporating some of Orochimaru's remains into himself, and mastering Edo Tensei, he's become a Kage-level threat with a small army of undead heroes and villains all prepared to Boss Rush the main cast. Between these moves, his ability to genetically engineer monsters like Manda II, and whatever else he's got up his reptilian sleeves, he's gone from Combat Medic to part of a Big Bad Duumvirate alongside Tobi, the series' Big Bad. And his latest revealed ability, Snake Sage Mode, even made Itachi go Oh, Crap!. If it wasn't for Sasuke, Itachi wouldn't have been even able to use Izanami on Kabuto. He had literally defeated Itachi twice there, first by impaling him from all sides with Mushi Tensei, then bisecting him after revealing he had mastered the powers of the Sound Four.
    • A justified example with the resurrected Sound Four who reappeared in a filler episode. The resurrected villains, now in immortal bodies with limitless chakra, are pitted against the same Konoha ninjas they fought one-on-one last time. However, last time the Konoha-Nin were just Genin (with Shikamaru being the only Chunin), but now all of them have become Chunin (with Neji having become a Jonin) during the Time Skip and gotten considerably stronger and more experienced since then. The Sound Four, who were all dead all those years, were unable to grow stronger and had no opportunity to learn anything new, resulting in them getting curb-stomped. The Took a Level in Badass trope is especially true for Shikamaru and Kiba, who were unable to defeat their opponents before the time-skip, whereas Choji and Neji almost died after barely winning their fights. In the rematches, Choji and Neji easily defeat Jirobo and Kidomaru without taking any risks, and Shikamaru and Kiba are able to easily defeat Tayuya and Sakon & Ukon without relying on any help.
  • Fate's minions in Negima! Magister Negi Magi fall under this; in their first appearance, they're perfectly capable of taking on the noncombatants of Ala Alba despite being outnumbered. Unfortunately, the next time Ala Alba shows up, most of the girls have either done additional training or pactio'd and obtained powerful artifacts, leading to an ignominious defeat for the minions, who haven't really improved since last time. Fate himself, while still a legit threat, reveals that the concept of training is quite alien to him. It shows, too. Every fight he has with Negi has Negi doing slightly better than beforehand until the final fight where Negi is doing a lot better and obviously has the advantage and WON.
    • Given her insistence she's a villain, it's justified for Evangeline, as with her power being sealed almost all the time she just had no way to improve — never mind she's already powerful enough to mop the floor with almost anyone in the series. Also averted: not only after being sealed she went and gained a minion capable with technology to cover for her scarce experience with it (leading to the first event of her power being unsealed, as there was a technological component to the seal), but when she was free to roam around she both increased her power, learned new skills (one of which results in her being still incredibly dangerous even with her power sealed), and invented new spells.
  • One Piece:
    • The Pacifistas. Nigh-indestructible cyborgs that shoot lasers. The Straw Hats were lucky to take down one of them. Cue the Timeskip. Luffy one-shots one, and Zoro & Sanji double-team another, though one hit from either of them would have been enough. However, Sentomaru does mention that he shouldn't have brought outdated Pacifista models from two years ago, hinting at the fact that the current Pacifistas are actually stronger — cue the Egghead arc, where Pacifistas Mk. III appear, which specs and weapons not present in the first models—. Predating those however, after the Warlord system is abolished and the Marines go to capture Boa Hancock (and Blackbeard eventually butts in for her fruit), the secret project Vegapunk was working on is finally unveiled: the Seraphims, Pacifistas modeled after the Warlords AND Lunarians, able to hold down both the Blackbeard Pirates and the Kuja, effectively rendering those first models even more So Last Season.
    • There's also Buggy the Clown. He's the first opponent Luffy actually had to work against (i.e. fight lasted more than one chapter), and after an attempt at revenge in Logue Town, disappeared from Luffy's sight, only appearing to comment on Luffy's progress. When he and Luffy meet again in Impel Down, the only thing that's different is the fact that his town-destroying Buggy (Cannon)Balls are now marble-sized.
    • The Seven Warlords of the Sea avert this. Just as Luffy grows stronger throughout his adventures, so do they, or at least do enough offscreen grinding to remain at the top of their game. The one exception is Moria, whose lack of training and over-reliance on his zombies made him rusty, to the point that he was eventually kicked out.
    • Downplayed with Rob Lucci. During their battle during the Enies Lobby Arc, Luffy had to go out and pushed himself to his physical limit to just barely endure Lucci's onslaught and defeat him. During their reencounter during the Egghead Arc, Lucci tells Luffy he's not the only one who's gotten stronger since then, and he's awakened his Devil Fruit powers. However, as the fight begins, it becomes quickly clear that Luffy is still a league above in terms of improvement, treating the duel like a joke, literally falling asleep easily dodging Lucci's hits, and knocking the wind out of Lucci in just one punch. He at least manages to clash evenly with Zoro twice.
    • Like his peer Lucci, Kaku gave Zoro one hell of a fight, and while he ultimately lost, it was a close one. During his rematch with Zoro, Kaku casually used a Rankyaku attack in human form that had previously been his ultimate attack, had required him to be in giraffe form, and required extensive prep time, but Zoro barely even noticed and blocked it with zero effort, and was more irritated at being woken up than anything. Even after going into his Awakened form, Kaku still couldn't scratch Zoro or make him treat him with anything other than flippant disregard, though Stussy knocked him out before he could do anything else, though it's still unlikely that he could have done anything to make Zoro even take the fight seriously, let alone turn it around. Pretty lackluster showing compared to his boss Lucci above.
  • Team Rocket regularly falls victim to this in Pokémon: The Series. While almost always Ineffectual Sympathetic Villains, usually they start each series managing to set up some halfway challenging battles and schemes with their newly captured Pokémon. However, as Ash and the others capture and train their Pokémon teams further, Jessie and James fail to bring out any new tricks and start getting curb stomped routinely. This is exemplified during the XY series; in many earlier episodes they were actually managing to be a persistent threat and the twerps regularly had a difficult time stopping them. During their final fight in the series, however, they lampshade it was bound to end up in Curbstomp Battles by the time Ash had become a league finalist, while they hadn't made a team change up since the eleventh episode.
  • When Ryoga finally manages to find his way back to Tokyo in Ranma ½, he immediately challenges Ranma again, who has spent the whole time having to fight several extremely strong opponents, most prominently Cologne. So the challenge turns into a Curb-Stomp Battle. Ryoga instead just asks Cologne to help him. And since Ryoga wants to marry Akane and Cologne wants to prevent Ranma from marrying Akane so he can marry Shampoo instead, she's quite willing to rather literally help him grind.
  • Subverted in Rosario + Vampire with Kuyou in his reappearance in the Fairy Tail invasion arc where he is shown to definitely have remembered to Level Grind, having grown a fifth tail. Double subverted in that Tsukune had level-grinded even more.
  • Viral from Tengen Toppa Gurren Lagann demonstrates the tendency of the trope to cross over with Ineffectual Sympathetic Villain. As dangerous as he is in his first appearance, he never goes down in personal capability (and improves with each appearance, in fact), but the heroes go up every time faster than he does, thus making poor Viral an increasingly weaker threat. Until his Heel–Face Turn, anyway. It didn't help that all of his improvements went towards his mecha's swordsman abilities (instead of his ranged attacks), which were completely useless in their first battle.
  • Averted in Toriko. Since the major villains also have Gourmet Cells, they are able to become more powerful just like the heroes. Tommyrod in particular went from keeping a level 81 insect hybrid inside himself as his ultimate trump card to becoming strong enough that one of his arms has a capture level of over two hundred. Starjun was already stronger than Toriko for most of the series, and after Toriko took a few hundred levels in badass Starjun still defeated him. Worse, the fight made Starjun's cells evolve, making him even stronger than before!
  • Near the start of Vagabond, Musashi is able to overwhelm several students at the famous Yoshioka sword school, but is probably at a disadvantage against Gion Toji, one of the senior disciples who is seen as the school's best swordsmen aside from the masters, is definitely at a disadvantage against Yoshioka Denshichiro, and isn't in the same league as Yoshioka Seijuro. When his duel against Denshichiro is interrupted, Denshichiro challenges Musashi to return in a year. An in-universe year and many volumes later Musashi returns and has been hardened by battle against formidable foes and growing from the callow youth he was in the early going to the start of the Warrior Poet he will eventually become, while they're mostly still where they were earlier. The difference from the early volumes is dramatic; now Musashi fights Seijuro evenly and eventually manages to defeat Seijuro, defeats Toji in a Single-Stroke Battle, and then gets the best of Denshichiro without too much effort, despite Denshichiro falling into desperation tactics and even trying to pull a Taking You with Me. Lampshaded by Seijuro, who tells his brother Denshichiro off for not simply killing Musashi when he had the chance, and says that Denshichiro wasted that year that he gave Musashi by not getting any better in the meantime.
  • In Yu-Gi-Oh!, hinted at in a mostly offscreen defeat in the Waking the Dragons arc and most notably the movie - in the series, Kaiba is defeated in a duel by Pegasus, the first season villain, to set up how much of a formidable opponent he is. By the time the movie rolls around, Kaiba duels Pegasus again and wins handily, implying it's because Pegasus was still relying on the same Toon deck and strategies he did in Season 1, while everyone else has moved on (it's also implied he's much less competent at the game without the use of the Millennium Eye to effectively cheat and see his opponent's hand). By the time of GX Pegasus, while still using the same deck, has notably improved, seemingly averting this after years to get used to the lack of his Millennium Eye and the aforementioned defeats motivating him to get better.
  • In Yu-Gi-Oh! GX this is averted hard with Trueman, the Starter Villain of the fourth season. Being made up of tainted cards who grows stronger with each defeated victim via taking their cards and strategies, when Jaden first duels him he's using a pretty mismatched deck that can pull off a semi-decent beatdown strategy, but nothing that Jaden really struggles with. As he returns with more cards he's able to pull off more effective strategies, culminating in the third duel against Jaden where he manages to summon two Five-Headed Dragons, considered to be among the strongest cards in the game, at once while disabling much of Jaden's own strategies. He further evolves to defeat and wipe out practically the entire cast of GX other than Jaden, Banner and Pharaoh, Jessie, and Atticus, if not the entire human race, by himself via his Me's a Crowd abilities before being banished for good by Jaden defeating his creator.
  • Lampshaded in Yuusha Gojo Kumiai Kouryuugata Keijiban, when Sage of the Forest bemoans the fact that the Demon Lord is still a useless level five two hundred years later, making his job harder (because Sage has been forced into the role of Hermit Guru in the setting's RPG Mechanics 'Verse, and now has to figure out a way to make the worthless level five Demon Lord a meaningful challenge even though they accidentally have two heroes).

    Comic Books 
  • Batman:
    • In canon, Batman is considered one of the world's greatest martial artists. However, with very few exceptions, most of his traditional rogues never attain anything remotely close to Bruce's level of fighting skill and have to rely on death traps, brute force in cases like Killer Croc, or hordes of thugs to take him on. This is justified in that most of them are mentally insane and don't have the same mental discipline Bruce has to improve their fighting skills. And even in individual cases like Penguin or Scarecrow who do study martial arts, Batman is still much bigger and heavier than them so the best Penguin or Scarecrow can hope for in a straight fight against Batman is to be Weak, but Skilled while in comparison to them, Bruce is Strong and Skilled.
    • At the end of Fear State, Batman accuses Scarecrow of being guilty of this. As he explains, most of his rogues gallery has done one of two things: doubled down on their gimmicks and gotten better or realized they're out of their depth and quit the business and do something better. Scarecrow, however, has stagnated in this, still relying on his fear tactics.
  • Averted by the Phantom Blot in the Mickey Mouse Comic Universe series "Darkenblot": every iteration of the Darkenblot Powered Armor features improvements on the previous one, to the point that when the 2.0 reappeared as built after its destruction Mickey was this close to declare it a fake built by a copycat until he noticed there had been a modification and it was in fact the 2.1. The police of Robopolis have caught on to this, so when they build four power armors to counter the Darkenblot they make them capable of taking not on the 2.0 they already met but on what they expect the 3.0 to be able to do... Only to find out that the Darkenblot 3.0 is much more powerful than anticipated when it casually wrecks the entire foursome in less than a minute.
  • X-Men: Dark Beast is initially a threat capable of beating up a young Nate while lecturing him - though Nate's raw power does still drive him off. Once Nate's powers are stabilised and mastered, however, Dark Beast's very sensible response to any sign of Nate's presence is to run away screaming.
  • An early issue of Fantastic Four has the titular team struggling with the Mad Thinker's Awesome Android who was so tough they were only able to defeat it by luring it into the Negative Zone portal. 100 issues or so later, the team takes out multiple androids of this type easily, and later on Sue defeats some by herself.
  • Immortal Hulk: Upon getting captured by Alpha Flight, Hulk gets taken to a space prison, where government stooge Henry Gyrich gloats to him about their new technology. If he shifts in size, the manacles he's bound in will automatically adjust to keep up. Unfortunately for him, Gyrich hasn't kept up with the Hulk's new powers, and he manages to escape when Bruce Banner's body bursts out of the Hulk's chest.
  • In Quicksilver's 1998 miniseries his primary villain is Exodus, an immortal psychic mutant who fashions himself as the heir to Magneto. Up to this point, Quicksilver has lost every battle he's ever had against Exodus, but in this mini, he gains the power of Isotope E, an artificial isotope developed by the High Evolutionary that acts as a MacGuffin form of Super-Empowering. While in possession of Isotope E Quicksilver's Super-Speed is boosted to Superman levels (he is described as literally being faster than thought now), allowing him to defeat Exodus for the first (and to date only) time.
  • Superman:
    • Mongul taught Superman his fighting style during Our Worlds at War. During a later fight, Mongul claims that there's no way Supes can win because Supes is the student while he is the master. Superman wipes the floor with him, explaining that he knows many other styles, like Rope A Dope.
    • Superman also utilised his superior knowledge of combat against his antimatter counterpart, Ultraman, in Trinity (2008): Superman observed that Ultraman killing his opponents made him weaker than Superman as he just killed his enemies in their first bout, where Superman's choice to spare them meant that he grew and improved whenever he had to face his foes again as they learned more about what they were capable of.
    • Who is Superwoman?: The titular villain defeats Supergirl pretty easily and quickly the first time they fight. Nonetheless, Supergirl is already familiarized with her tricks when they battle again, and she nearly kills Superwoman. When they square off for the third and final time several months later, Superwoman has not mastered her powers or developed some new ability or fighting technique, whereas Supergirl has gained greater combat experience, and she defeats Superwoman off-panel and with no visible struggle.
  • Wolverine's most well-known enemy is Sabretooth, a psychopathic Serial Killer mutant who has a nearly identical mutation to Wolverine but is bigger, stronger, and just plain meaner than the ol' Canucklehead... at least, that's the way it always starts before Wolverine gets either an adamantium upgrade from Weapon X or some much-needed motivation to fight Sabretooth on his level. Either way, the end result is Creed getting left in the dust. Sometimes, like in X-Men: The Animated Series, these events have already played out in the backstory, reducing Sabretooth to mere Starter Villain in the present day.
  • Played with in the W.I.T.C.H. comic: At first Cedric is a massive threat due to the same reasons as in the cartoon and being extremely cunning, then the Guardians, being more powerful to begin with, achieve the experience to take on him, but by the times of the final battle of the first arc Phobos turned him into a creature capable of taking on all of them and winning, and they barely defeat him due to the Crown of Light having been enchanted to absorb the energy of whoever wears it (including Cedric's, when Will puts it on his head). He's later imprisoned in the Tower of Mists, where he can't get better... But when he's broken out in the fourth arc he's an even bigger threat than before, as he knows he's now outmatched in a direct battle and relies exclusively on his wits, and he happens to be one of the smartest characters in the series. To the point that in the fifth arc, when he's released on probation, Orube is terrified when she stumbles into him (and he's now powerless), something that proves justified when, improvising he casually tricks Matt into being imprisoned in the Book of Elements in spite of Matt having been warned exactly of who he was, with the Guardians unable to make him pay because he's necessary to get Matt out.

    Fan Works 
  • Equestria Girls: Friendship Souls: Played with, in that the Soul Reapers, Arrancar, and Quincy have been grinding anywhere from years and decades to centuries and millennia to get as strong as they are, but Sunset, the Humane Five, Human Twilight, and Adagio are, to put it bluntly, freaks that have gained and honed their powers in just weeks to close the gap. In other words, the heroes are on an exponential curve thanks to their Equestrian magic acting as The Gift while the villains are on a linear one.
  • Played with in Stallion of the Line. Smoker can't beat Luffy when they first meet but his powers are unusual enough that Luffy has to work for his victory if he doesn't want to use haki. However, despite Luffy warning him to, Smoker doesn't pick up any new tricks and uses the same tactics in subsequent encounters, causing Luffy to defeat him with ease each time. Contrast Hina who changes her tactics since not only do her normal ones not work but Luffy's already seen them and would have counters prepared. Luffy at one point asks if he can have Hina chasing him instead since she keeps things interesting.
  • To Hell and Back (Arrowverse): Just like in canon, Malcolm Merlyn. Interestingly, this becomes evident in the story's equivalent to Arrow Season 1; according to the author, this is a logical deduction of Malcolm's current level. As he only had spent two years with the League of Assassins and had no sparring partners on the same general level as him to push him to be stronger, he is no match for Oliver, who, despite being younger than him, has seven years of training and Barry and Kara as frequent sparring partners. Thus, when he and Oliver first clash, it's a Curb-Stomp Battle in favor of the latter.
  • The Bridge: At the start of the Enjin arc, the Sirens and Monster X can't do much to stop Enjin because the sirens' magic is weak and X is suffering Power Incontinence with his abilities. At best when they decide to do an Enemy Mine is X can hold Enjin off with close-quarters combat agility and the sirens can get the getaway van ready. Later on thanks to Aria Blaze mastering her new powers and helping X reacquire control over his own, they start to catch back up. It's still an extremely hard fight but ultimately they win because Enjin never got any stronger and they exploited its weakness. However, Enjin's master Bagan then revives Enjin and gives it a powerup, then it captures Aria and uses her as a battery. In the rematch, X manages to unlock new power and Aria partially breaks free, and Enjin is beaten again.
  • Justified in Son of the Sannin with Mizuki. He was defeated at the end of Part I by Rock Lee and executed for treason against Konoha. Fast-forward a hundred or so chapters to the Fourth Ninja War, aside from his zombie "immortality" when he's brought back via Edo Tensei, he's not any stronger than he was back then. To drive the point even further, he's pitted against his former students (Zaku, Kin, and Dosu), whom he calls "useless failures", and they retort they were useless only because he didn't teach them anything. They proceed to show him how many levels in badass they took under Anko Mitarashi.
  • Miraculous Alliance: Played with:
    • At first played straight for Hawk Moth, and justified: a Miraculous user is usually chosen as a teen so their powers will develop quickly, but Hawk Moth is already an adult and his powers will take much longer to increase... Something Nooroo purposefully hid from him until directly asked.
    • Then defied once Hawk Moth asks Nooroo why he isn't unlocking new abilities, forcing him to reveal the existence of a potion that forces the development.
    • During the final battle, the returning Akuma Champions are just as strong as they were during their first summoning. Copycat gets this spelled out for him by Ladybug during their fight-one much more unbalanced than he had expected.

    Films — Live-Action 
  • The Dark Knight Rises: When they first fight, Batman treats Bane as a regular criminal, is out of shape, and suffering from the psychological, emotional, and physical consequences of being a city's protector. As such, Bane tears him apart. The second time they fight, Batman is fighting with a renewed sense of purpose, knows how to fight Bane, and might actually be in better shape than he was last time (despite the previous fight ending with Bane breaking his back). So this time around, he is able to fight on largely equal terms and eventually gets in a lucky hit to Bane's mask that keeps Bane supplied with painkillers to mitigate the injuries Bane suffered years ago. From that point forward, Batman easily dominates the remainder of the fight.
  • Done across movies, for a single move. In The Desolation of Smaug, Bolg caught Legolas's sword by pinning it between his arm and body, and then pulled Legolas in close and pummeled him. He repeated the move against Legolas, this time wielding his knives, in The Battle of the Five Armies, only for Legolas to grab Bolg's arm, leap up onto his shoulders, and stab him through the head.
  • In Jason X, the classic incarnation of Jason Voorhees, infamously unstoppable in the 20th century, gets repeatedly juggled and eventually shot to pieces by a medical android upgraded with combat subroutines, something that's a few hundred years well beyond his time. However, after being upgraded himself by the ship's medical bay, the new Jason X is able to destroy said android quite easily.
  • Marvel Cinematic Universe:
    • By the time of Thor: Ragnarok, the eponymous God of Thunder has long outgrown his original boisterous Action Hero personality and become quite wise to his brother Loki's trickster ways; as such, when Loki makes an attempt to betray him during their escape, Thor sees it coming a mile away and has a trick of his own planned. The page quote is Thor explaining this very trope to a paralyzed Loki as the latter is lying helplessly on the ground after being basically tasered by Thor. Fortunately for Loki, he does get better by pulling a Big Damn Heroes moment and saves all of Asgard's people before Thor is forced to unleash Surter to destroy their home to stop Hela, suggesting he will get better... only for Thanos to kill Loki when his old habits prove Thor's point ''exactly'' right.
    • In Spider-Man: Far From Home, the titular Wall-Crawler gets Mind Raped by Mysterio, led into a train, and rendered completely helpless after being tricked into giving him E.D.I.T.H. which enables him to control an army of advanced drones. However, by the final battle, Spidey has both fully mastered his abilities and creates a new Upgraded suit, and in the resulting fight Mysterio can only watch as his plans fall apart. First, Spidey goes through an army of his drones by himself. Then, Mysterio tries to blind him only to learn that Spidey is so in-sync with his Spider-Sense that he can now dodge every attack without sight. Finally, Spidey takes him out in a single hit.
  • Mortal Kombat: Annihilation: Exaggerated with Shao Kahn, who is an ancient warlord that is nigh-invincible due to his immortality (only fellow immortal Raiden can put up a fight against him) until the finale, where he is Brought Down to Normal by the Elder Gods as punishment for breaking the rules of Mortal Kombat with his invasion. This forces him, quite possibly for the first time in his extremely long life, to fight a mortal with only his own strength and skill to rely on. Being a Smug Snake at his core, he comes up rather short of both in the end.
  • In The Mummy Returns, while arguably justifiable as Anck-su-namun has spent most of that time dead, when she and Evelyn fought after Evelyn regained her memories of her past life as Nefertiti, Anck was totally reliant on her combat training from Egypt, whereas Evelyn was able to take her by surprise with some tricks she'd learned from Rick since their marriage in the present.
  • Played with in Pacific Rim, as it's clear that both Jaeger development and Kaiju size class were progressing since the Rift was opened. In the battle of Hong Kong, two category 4 Kaiju's managed to destroy two Jaegers, one Mark I and one Mark IV, and incapacitate another, a Mark V, with Kaiju essentially designed to take down those specific Jaegers. The climax involved two categories, 4 Kaiju's, and a category 5 against a Mark IV and a Mark V, which they only won via a suicide Nuke 'em strategy. It wasn't until very late in the war that the humans realized that this wasn't the case with the Kaiju. In Pacific Rim: Uprising when the Kaiju return two category 4's and a category 5 went up against four Mark VI Jaegers, as they did not spend the ten-year Time Skip slacking off on Jaeger development. The fight was dominantly in their favor, at least until a surprise move using nanobots to do fuse all three into the Mega Kaiju changed everything.
  • In X-Men Origins: Wolverine, Victor and Jimmy's first fight is a Curb-Stomp Battle in Victor's favor. Then Jimmy gets his adamantium and wipes the floor with Victor.

  • Averted in the book series 1632. At first, the American weapons from the year 2000 vastly outclass the weapons of the time. After research and development, using espionage and the American Library for reference, the weapons disparity is greatly reduced.
  • The wolves in An Outcast in Another World that gave Rob so much trouble in the early chapters no longer pose any threat to him once he Levels up more and gets sufficient combat experience.
  • The Beginning After the End: The Scythes end up being a major example.
    • When first introduced, the Scythes were Knights of Cerebus, being the much, much stronger Evil Counterparts to the Lances, themselves the strongest mages on Dicathen. Given how the Lances save for Arthur were struggling to beat the much weaker Retainers, it goes without saying that fighting the Scythes is a death sentence. At the end of the war, Arthur is forced to go up against two Scythes at once - Cadell - the strongest among the Scythes and a prolific Hero Killer who killed his Parental Substitute, the dragon Sylvia - and Nico - his Evil Former Friend from his past life and the true identity of Elijah Knight - and barely survived thanks to Sylvie's Heroic Sacrifice.
    • However, once Arthur Came Back Strong as an aether-wielding demigod, he was able to turn the tables on the Scythes as while he had gotten stronger, they had not. During the Victoriad, Arthur effortlessly knocks out Nico in a Single-Stroke Battle followed by him slaying Cadell. In the aftermath, Agrona attempts to alleviate the power disparity by creating more powerful regalias for them starting with Nico, but at this point Nico turns out to be a Bastard Understudy who has began covertly working to break free of Agrona's control, meaning only he out of the remaining Scythes Averted this trope (as it has not been confirmed if the other Scythes received these regalias).
    • The Scythes were intended to act as Agrona's generals for his invasion of Dicathen as due to the treaty that defines the Divine Conflict no Asuras are allowed to directly participate. As the Scythes are only Vritra-blooded Alacryans and not true Asuras they are allowed to participate. For the actual war with Epheotus, Agrona has the Wraiths, dedicated Asura-killers considered by the Alacryans as semi-mythical bogeymen, and the Legacy, a reincarnated Person of Mass Destruction whose complete dominion over mana allows her to drain the mana from Asuras which is fatal to them. Agrona intends for the Legacy to be an Aversion as he wants her to go up against Arthur to not only become stronger herself, but also to reveal the true nature of power in the world. As such, by the time Agrona begins preparing to invade Epheotus, he neglected empowering the Scythes now that they had fulfilled their purpose.
  • Cradle Series: Averted; when Lindon has a duel with a Highgold in a year's time, Eithan promises him that with training, he'll have a good chance of defeating a Highgold by then. After Lindon leaves, Yerin notes that Eithan didn't mention his opponent won't be a Highgold by the time of their duel, since he just got his hands on a weapon that gives him a Cannibalism Superpower.
  • Inverted in Darth Bane: Rule of Two. During the ten-year Time Skip, Darth Zannah went from being a 10 year-old child who was strong in the Force but had very little training to a powerful Sith sorceress capable of using the Force to thoroughly and completely break someone's mind until whatever's left is begging for death. In that same time skip, Johun went from age 19 to 29, but because he was assigned to Chancellor Valorum, he spent more time learning politics than practicing with his lightsaber and Force abilities. As a result, when he and the other Jedi face off against Bane and Zannah in the climax, Johun himself is the weakest fighter in the room. Granted, he and Zannah had never even met before then, much less fought, but if they had, he would have been all but guaranteed victory.
  • The Solarian League Navy in the Honor Harrington series has spent literally centuries as the biggest, baddest navy out there. Able to push around any "neobarbs" who got uppity with no problem. In their arrogance over that fact, they never developed much in the way of new technology themselves (so as not to change their own balance of power) and disregarded anything Manticore and Haven came up with as inherently inferior, despite the two-star nations' recent Lensman Arms Race. In later books, they're learning the hard way just how far behind the curve they are now as every battle they've fought with Manticore has been a Curb-Stomp Battle in Manticore's favor despite being vastly outnumbered every time. What they can't catch up as quickly on is that members of the Manticore-Haven alliance have spent decades at war and as a result Darwinian selection has largely separated the wheat from the chaff among their senior officers and military, leaving a collection of highly competent, experienced commanders leading efficient, veteran military forces. The SLN, meanwhile, has most of their senior commanders appointed strictly due to their seniority and/or political connections or personal ability at sucking up instead of actual talent while their crews are largely inexperienced in war. The end result is not only a navy that's horrifically outgunned but one led by people too stupid or ignorant to realize how outgunned they are.
  • In Isaac Asimov's story In a Good Cause—, a large alien empire seems to be on the brink of conquering the squabbling collection of human worlds. It doesn't turn out that way: the squabbling had led the humans to refine their military technology and tactics to the point that the first human world to seriously confront the rather stagnant alien empire easily defeated them, even before other human worlds started putting aside their differences to join up with the winning side.
  • Noted to be a problem for Adventurers based outside Orario in Is It Wrong to Try to Pick Up Girls in a Dungeon?. Adventurers living inside Orario have access to the Dungeon, offering both more opportunities to level grind as well as stronger opponents. Outside Orario, the monsters are generally weaker and rarer, meaning those outside the Dungeon City have both less chance to gain levels and the chances they do get are of less benefit in terms of levelling or developing skills and abilities. The end result is for outside Adventurers to generally top out around Level 3, while in Orario Level 3 is considered mid-range at best; and so most Familia heads are Level 4 or 5 with the Loki and Freya Familia boasting multiple Level 6 adventurers, and the Freya Familia has among their members Ottar, the only known Level 7.
  • In Percy Jackson and the Olympians, the first supernatural monster Percy ever fights is the Minotaur in The Lightning Thief. The confused, then-twelve Percy is barely able to kill him. But monsters in this 'verse all have Resurrective Immortality. So the Minotaur comes back in The Last Olympian for round two with the now-sixteen well-trained demigod Percy. The Minotaur promptly gets absolutely stomped in a few seconds by the demigod.
  • This is an invoked trope as a strategy in the Safehold series. The Gbaba win a long war of attrition against humanity due to superior numbers and initial starting technology, but human researchers discover they haven't advanced in possibly millennia and show no inclination (or possibly ability) to do so, even as they face increasing losses due to humanity racing to catch up, and they realize that if humanity had only had a few more years of their normal technological advancement, they'd be on even terms and then shortly thereafter curb-stomping them. They establish a secret colony at Safehold where the last survivors of humanity can hide, with the plan being to create a place where humanity can regrow a significant population and then continue their technological advancement so that when they emerge from hiding, humanity can get revenge on the Gbaba from a point of superiority.
  • In the Starfire series, the members of the Grand Alliance get curb-stomped on a regular basis by the might of the Bug forces they oppose. After a while, they come to realize that they face overwhelming force because they're facing fleets that have been built up over centuries, but only come from a handful of systems so there's no way that the Bugs could have the infrastructure to replace them as fast as they're being lost, nor make significant changes in the technology they deploy because they're using ships they built a long time ago. Once the allies realize this, they begin fighting battles of attrition because they can afford to replace ships and the Bugs can't. By the end, they can routinely beat outnumbered Bug fleets and start becoming more concerned with winning the war quickly to keep their own casualties down.
  • Explicitly stated by the analysts of the Rangora who are trying to figure out how to beat the humans in Troy Rising by John Ringo. In 17 years the humans went from being ruled by a single crappy Horvath cruiser, to having multiple battle stations that can defeat entire Rangoran invasion fleets (which wiped the floor with the Horvath and are busy conquering everybody else in sight), since no other race in the galaxy has felt the need to improve their technology in thousands of years. In Chapter 30 of "Citadel", the Rangoran analyst's models show the Rangora could not have matched what Earth has already done in those 17 years, that with the current two battle stations the Rangora will not be able to successfully invade and defeat the Earth system, and that within 20 years the additional three battle stations that are actively being built will enable the humans to invade and defeat the entire Rangoran Empire.
  • At the beginning of The Wheel of Time, Rand is barely capable of killing one Trolloc. Fast forward three years and he's annihilating 100,000 of them by himself.
    • Myrddraal, the minor Humanoid Abominations that act as Elite Mooks and field commanders for the Shadow get this, too. In the first book, they're terrifying and treated as Run or Die, basically. The next couple of books they're still really tough, but the protagonists get better at dealing with them. Later in the series, they're only slightly harder to kill than Trollocs. Of course, this was foreshadowed in the first book — Moiraine explicitly points out that any even somewhat skilled channeler can beat them without much trouble, and by the midpoint of the series all the protagonists are either quite powerful channelers or have some other ability to put them on that level.
    • Happens to some of the Forsaken. They find that the heroes have done things they never thought possible in their own time. And others are simply flattened by the heroic mooks, rather than the protagonists. Notably inverted by Demandred, who did level grind while running around in Shara and at one point boasts that he's become more powerful than he ever was in the Age of Legends; his performance during the Last Battle bears this out.
  • In Worldwar, a race of lizard-like aliens scouts out Earth during the 12th century and spends the next eight centuries preparing for an invasion. Problem is, their technology progresses very slowly, so they arrive on Earth in 1942 expecting to face knights and archers... and run right into tanks, machine guns, airplanes, and The Bomb.

    Live Action TV 
  • Agents of S.H.I.E.L.D.: Grant Ward's brother Christian was built up as a sociopath who tortured Grant and their little brother for years, culminating in Grant's Start of Darkness when he tried to kill Christian by burning their home down. By the time they meet as adults in Season 2, Grant has become a badass secret agent trained in infiltration and assassination with expert knowledge of multiple weapons and martial arts. Christian is a rich senator and is implied to hold a lot of political power, but has no more fighting prowess than a normal man would. The result is that Grant manhandles him with ease, forces him to confess to his crimes, and then kills him offscreen without any fanfare.
  • Arrow: Malcolm Merlyn was able to defeat Oliver quite easily when they fought each other in the first season. When Oliver faces him in Season 4 for leadership of the League of Assassins, he defeats Merlyn with hardly any effort at all, the more impressive as Oliver was holding back because he didn't want to kill him.
  • In Buffy the Vampire Slayer in the first season, the first Big Bad, The Master, was shown as this terrifying, ancient vampire whose history of atrocities was enough to plague Buffy's nightmares and was able to easily imprison and torture Angel in an alternate universe. By Season 8 in the comic series, both had progressed to the point that a possessed Angel was able to shatter his skull when he was temporarily revived.
  • In Doctor Who the Daleks were a serious threat in earlier episodes, but every time the Doctor defeats them, they become less credible; by the end of the original BBC run, Daleks were nearly laughable. See also Depending on the Writer, because sometimes the Daleks really were laughably ineffectual, and sometimes the Doctor was just that good. The new series then proceeded to slap this trope in the face by making the Daleks the terrifying unstoppable killing machines they were are the beginning, and a very serious threat every time they appear.
  • The Flash (2014) provides an interesting variant, where it's not that a villain forgot to level grind as much as that he just hasn't leveled grind yet. In Season 1, the Reverse Flash was stronger, faster and a better fighter than Barry repeatedly defeated him and required help from multiple allies to be taken down. Season 2 episode "The Reverse-Flash Returns" has him come back... except he turns out to be a time-travelling earlier version of him who is meeting the Flash in person for the first time, going against a more experienced Barry. As a result, when they do fight, Barry takes him down relatively easily. When Barry encounters the Reverse-Flash again in Crisis on Earth-X, Thawne once again provides a challenge for Barry, although Barry does defeat him in the end. When the Reverse-Flash returns for the Season Seven finale, he attempts to battle what he thinks is a weakened Barry after helping take out Godspeed... only for Barry to drop him in one hit, leaving him utterly confused.
    Eobard Thawne: It's just you and me, Flash. I've been waiting for this moment for a long, long time.
    Barry Allen: I'm only gonna say this once. Walk away while you still can.
    Eobard Thawne: Allen. You are too weak to stop me. And I'm just getting started.
    [Barry goes into Flashtime to stop Thawne's attack and tosses him to the pavement]
    Eobard Thawne: What did you do? I created you. I taught you everything you know! Everything you are because of me! What did you do?
    Barry Allen: I got faster. Didn't you?
    Eobard Thawne: No. But I will, Flash. Mark my words. I will.
  • In Highlander, Xavier St. Cloud used to be considered one of the deadliest immortals in the world, and trying to fight him was considered a death sentence. However, he eventually stopped fighting and focused on stealing to support his lavish lifestyle. As a result, either his sword skills decayed or his old rivals like Duncan MacLeod improved enough to beat him.
  • Happens in a number of Kamen Rider shows, for various reasons:
    • Kamen Rider Double antagonists, the Fantastic Drug-using Dopants, are restricted by a level cap based on their compatibility with the type of Gaia Memory that they use: the only way to get stronger is to find a Memory that they're more compatible with. One villain doesn't know about the cap, tries to level grind, and meets a messy end because of it.
    • Kamen Rider Gaim sets up several antagonist Riders who begin far more powerful than their heroic counterparts, but most of them never gain more powerful forms or gain them much more slowly than Gaim does. Oren Pierre Alfonzo begins as a powerful villain as Kamen Rider Bravo but soon turns into a recurring joke, while the New Generation Riders are the central threat during the second quarter of the series, but are permanently outmatched once Gaim and Baron gain forms rivaling or exceeding theirs. The only villain to avert the trope is Kamen Rider Duke, who is shown constantly upgrading his armor (which was an Ace Custom to begin with) and remains a threat until his death.
    • Kamen Rider Ex-Aid is the only show to avert this trope for every monster, as every Bugster increases in level each time they're defeated. The trope still plays out due to the Riders leveling up faster and gaining more experience than the Bugsters do, but they make a lot more of an effort to stay relevant than returning monsters usually would.
    • Kamen Rider Build has this trope on purpose, as the Build System and Transteam System were both parts of a secret government Super-Soldier project. The Build System can grow stronger but requires surviving exposure to highly toxic gas in order to use; by contrast, the Transteam System can be used by anyone but can't grow beyond its initial parameters and was relegated to being an "aggressor" to help Build get stronger through combat. One of the two villains using Transteam discards the now-useless power in favor of becoming a proper Kamen Rider himself, while the other gradually reveals that he was already far more powerful than anyone else in the show. By the time the heroes actually catch up to him, he gets his hands on his real Transformation Trinket, outs himself as the Big Bad, and spends the entire rest of the show constantly level grinding to ensure they can never catch up again.
    • The Another Rider monsters from Kamen Rider Zi-O, who've stolen the powers and histories of the previous Kamen Riders, are implied to be unable to level grind due to being unworthy of the power they've stolen. If anything the stolen powers get weaker over time, so that an Another Rider is at its strongest when it's first created.
    • Kamen Rider Zero-One:
      • The beginning of the series sets up the villainous Kamen Rider Horobi as being far beyond the human Riders at first, but by the end of the first quarter, he's surpassed and defeated. His dragon Jin only fares slightly better, as getting dangerous to avenge the fallen Horobi only gives him enough of a power boost to elevate him to Disc-One Final Boss status.
      • The cycle then repeats itself with the next villain, Kamen Rider Thouser. Thouser initially manhandles the heroic Riders, but eventually proves to be Unskilled, but Strong; he relies entirely on his suit's strength and falls short when more experienced fighters use upgrades to close the power gap. Even Horobi gets the better of Thouser when he comes back in play, without upgrades as he was Strong and Skilled to begin with. For extra irony, Thouser freely gave the Riders the upgrades used to beat him: For Zero-One he had intended for it to be a Deadly Upgrade (that also locked Zero-One out of using any of his other powers), never expecting that Zero-One's friends would find a way to counteract The Berserker side effects. And then he handed one to Vulcan because he thought he was brainwashed and under his thumb, but underestimated Vulcan Fighting from the Inside and taking back control.
    • Kamen Rider Saber:
      • Zig-zagged by Kamen Rider Calibur, the antagonist of the series' first arc. When he first appears, he proves to be a formidable challenge for any of the heroic Riders, and even gets an upgrade that puts him head-and-shoulders above everyone else to the point where it takes the three main Riders in their then-current upgrade forms to even beat him once. Then Saber gets his next upgrade, which allows him to wipe the floor with Calibur one-on-one.
      • Happens again with Kamen Rider Solomon, the antagonist of the second arc. Upon his debut he trounces all the Riders even as they fight alongside each other, but after Saber again gets his Super Mode, the tide changes from him handing out curb stomps and being on the business end of a multiple-episode long Trauma Conga Line.
    • Kamen Rider Revice: Oddly enough, this happens in the case of the show's Designated Girl Fight between Sakura/Kamen Rider Jeanne and Aguilera. Early on in the show, Aguilera manages to comfortably defeat Sakura; but as the show progresses, Sakura undergoes Character Development while Aguilera is hit with a Trauma Conga Line and becomes an emotional wreck. As a result, Sakura begins to gain the upper hand, culminating in a Curb-Stomp Battle in her favor by the middle of the series. Thankfully, Sakura is merciful enough to guide Aguilera through a Heel–Face Turn; and soon after Aguilera gets a Redemption Promotion and becomes a Kamen Rider herself.
  • Power Rangers:
    • This usually happens to generals, since at the beginning of the season they are usually able to fight all the rangers at the same time, and even win with relative ease. The more the season progresses the difference usually narrows, to the point that by the end of the season, a lone ranger (usually the red one) is able to beat him on his own.
    • Power Rangers Zeo: When King Mondo battles the Rangers partway through the series, the latter are barely able to win thanks to their new Super Zeo Megazord. Later when Mondo is rebuilt and confronts the Rangers in the season finale, they don't even need to use their Zords, just grow to giant-size themselves to deliver a Curb-Stomp Battle. As explained in Mighty Morphin, the Zeo Crystals constantly grow more powerful over time, whereas King Mondo was rebuilt to how he was prior to being destroyed.
    • In Power Rangers Jungle Fury, the overlords Jellica and Grizzaka end up suffering from this, especially in comparison to Big Bad Dai-shi.
      • Jellica when introduced in the second part of the series, she was so powerful that she would have killed the Rangers if not for outside interference, and she was able to hold an even fight against the Big Bad Dai-shi/Jarrod, and she was winning. By the end of the second part of the series, Dai-Shi is so out of her league that he is able to easily defeat her while he is busy with another fight.
      • Grizzaka with the power of the Zocato, was so powerful that he soon dethroned Dai-shi, by the end of his story arc, Dai-shi also learned the Zocato and was able to stop his attacks without showing effort.
  • Averted in the Stargate-verse. At first, when humans get Ancient technology in Stargate SG-1, they can curb stomp the Go'auld. Fast forward a few years, and their new ships can ignore the human beam weapons and destroy them. This is also shown in Stargate Universe, where the Lucian Alliance is able to engage Earth's most advanced ship, the George Hammond (equipped with those same plasma beams), with three upgraded Ha'taks, and the Hammond receives substantial damage in the fight. Word of God is that the Lucian Alliance (largely composed of humans) has every incentive to upgrade their tech, unlike the Goa'uld, who spent millennia sitting on their asses.
    • The expectation of this trope is such that the writers had to answer it publicly. They got a lot of flack about it — since ships like the Hammond can fight Ori ships, which can easily beat the first human ships beefed up with Asgard tech, which could easily beat the Goa'uld ships they were intended to go up against when three pyramid ships hearkening back to the original movie showed up, everyone expected it to be like the Death Star vs the SS Minnow. When it wasn't, the fandom went nuts and the writers gave the obvious, simple answer: Did you think that while Earth kept advancing, the rest of the universe had stood still?
  • In the Star Trek series:
    • When the Borg appears first their Cubes are unstoppable even by an entire fleet of Federation ships and must be beaten by trickery. By the time Star Trek: First Contact comes around, increased fleet size and new technology mean the Cube is far from unscratchable, although it does still take Captain Picard hearing the voice of the collective to find a weak spot to finally destroy it.
    • Then you have the Voyager series finale, where the titular ship uses technology from 20 years in the future to One-Hit Kill Borg Cubes with the Cubes barely able to scratch the paint on the ship. The Borg ends up assimilating the new tech, but due to a virus infecting the Borg Queen, only get it implemented on one sphere that conveniently pulls Voyager inside itself so it can be destroyed from within.
    • In the case of the Borg, it's not so much that the villain forgot to level grind as that the villain is incapable of level-grinding the conventional manner. Voyager establishes that the Borg are completely incapable of invention or innovation. The only way they can grow is through assimilation...and most of the technology in the Delta Quadrant that was worth assimilating already had been. The rest was in the hands of those smart and/or powerful enough to avoid assimilation. Essentially, we have an entire villain faction that had already hit its level cap, while the heroes haven't and thus can keep on grinding. This is the main reason the Borg have trouble with Species 8472 (STO calls them the Undine), whose extremely aggressive immune system prohibits assimilation, which also applies to their extremely capable Organic Technology.

    Tabletop Games  
  • Inverted by the Clans in BattleTech. While the Inner Sphere blew themselves back to a technology level before that of the peak of the Star League in a three-century war, the Clans (having left before said war started) continued to improve the weapons technology to the point that the 'Mech designs and weapons they bring in their invasion seem flat-out impossible, which combined with the rigorous training the Clanners go through means that the only battles the Inner Sphere forces win early on are usually won through superior tactics, outright trickery, and the Clans only bringing four out of the almost twenty Clans on the invasion. Also played straight on a philosophical level by the Clans — their belief that a warrior is past their prime by thirty means that their warriors have far less time to level grind compared to the soldiers in the Inner Sphere, who have been known to fight until their seventies, with all the combat experience that comes along with it. The Clans also fell into this on a technological basis - while they refined Star League technology to unprecendented levels early on in their isolation, their technological advances then fell into relative stagnation, and it wasn't until after the invasion that the Clanners started creating new technology again.
  • Magic: The Gathering has the skyships Weatherlight (the heroes) and Predator (the villains). When the two battle in Rath, the Weatherlight is outgunned and the heroes only escape through dumb luck. By the time of the Rathi Overlay in the Planeshift storyline, however, the Weatherlight had a more experienced crew and upgraded weaponry, and when the two skyships battled again, the Predator was thoroughly trounced.
  • Scion: Ragnarok notes that given how they started out Garm in Demigod, most players would probably be able to beat him into a fine paste at the God level of power, and advises Storytellers to avert the trope by giving him an appropriate stat boost when he fights Tyr (the justification being that Garm's had plenty of time to level-grind on Scions and Demigods on his way to Ragnarok).
  • Can be invoked by good optimization tactics in any tabletop RPG that allows the players to customize their characters during creation. Will be invoked by Monty Haul gameplay. As such, this trope has the potential to appear prominently in nearly every tabletop RPG. It's also likely to happen in a much more literal sense: as the players level up their characters, monsters that were a significant threat previously challenging will become laughably easy opponents in combat, while monsters that the players previously viewed as far too powerful to challenge directly will likely end up crushed beneath the players' boots. And there's the possibility of evil NPCs either not levelling up as fast as the PCs or not levelling up enough to keep up with the player's new powers. Some GMs invoke this trope for dramatic effect.

    Web Animation 
  • Counterspell: Inverted. Due to the actions of Black Mage and Bruiser, the heroes end up being severely under-leveled on account of having nothing to fight and no way to gain the experience needed to handle powerful enemies.

  • The Adventures of Dr. McNinja:
    • Parodied when the Doc easily dispatches a vampire; the Alt Text snarks that he had lived 126 years without ever thinking to take a karate class.
    • Another parody example pops up during the Paleontologists, Politicians and Prologue arc, where McNinja takes down Franz Rayner and Mongo the Uberninja with ease.
      Doc: See, I've fought you guys enough, you basically aren't level bosses anymore. It's like a video game! Boop boop!
  • In Captain SNES: The Game Masta:
    • Everyone in the world of Final Fantasy VI freaks out when Kefka is brought Back from the Dead, up until they find out he's just as powerful as he was the last time they did battle! Unfortunately for him, the heroes had been guided by a player who power-levelled them so badly that Locke killed him so fast (repeatedly, thanks to multiple resurrections) that eventually the biggest complaint was that no one else was getting a turn, and then when Locke proceeds to let everyone else go, they find it unsatisfying to take him down in one hit. Kefka eventually turned the tables by taking the kid who was resurrecting him, hostage.
    • In the world of Final Fantasy IV, Edwa...erm, Spoony has a subplot to take revenge on Cecil and Rosa with his new Antlion, with over twice the HP it had before! But since Cecil is topped off at Level 99 with 9999 HP, he one-shots it. Turns out it was all part of the plan.
  • Dragon Ball Multiverse:
    • The trope is zigzagged, with many of the original series's villains having set up Villain Worlds and not seeing the point in pushing their limits without competition. Freeza's family and troops, Bojack's gang, and Dabura haven't improved at all from their original level of skill, and the Androids are actually breaking down from lack of maintenance. However, Cell's Blood Knight attitude has left him training constantly since the Cell Games (it's implied he could give Mystic Gohan a fight), Buu's been on an all-absorption diet since the end of the series and won the Superpower Lottery to begin with, and Broly's power requires no training to grow.
    • Also subverted with U8 King Cold, who if his family's statements and expanded universe material are any indicators, has gotten stronger since Freeza was born, as he once couldn't control his power in his higher forms at all, but now spends most of the tournament in his final form with no problem at all, much to Cooler's shock, and is powerful enough to curb-stomp U3 Bardock when he uses 100% power, something he can access in seconds as opposed to the minutes it takes his son. Then he goes One-Winged Angel. Twice. Justified in that he's actually Ginyu who stole his body, and he knows better than not training.
  • In FreakAngels Mark doesn't exactly forget to level up, but does ignore the possibility that the Freak Angels might have done so too. He's just surprised when Kait disintegrates his sword, but totally unable to cope with Arkady's ability to teleport.
  • Kid Radd: Radd and his older brother Gnarl, originally from the (fictional) NES game Kid Radd where Gnarl served as the final boss underwent this, both in their original game, and later in the "real world", i.e the Internet; Gnarl was much stronger when they first fought, both in his base form, and his One-Winged Angel form, the Gnarlbot, mainly because of the inexperience of the real-life player controlling Radd in the game. As the player got better, Gnarl became much less of a threat, which carried over when the game characters were liberated. Unlike Radd, Gnarl had difficulty moving beyond his programming, and still stuck to the same level of power he had in the game, while Radd grew far beyond that (albeit mostly by necessity).
  • Subverted in The Order of the Stick, where the Genre Savvy Haley realizes that no matter how much stronger she gets, her personal rival will somehow always get more powerful offscreen. Later on, said rival argues against her boss who just wants to kill her because she'd like to gain a few more levels for free. It still applies outside of game mechanics; Haley needs to be saved in their first battle, but completely curb-stomps her in every later encounter (when Crystal doesn't have a small army backing her). A big part of this was that she only gained actual mechanical levels, while Haley was getting better gear and becoming a more tactically skilled combatant.
    Crystal: [playing poker] Sweet! Starshine gained a level!
    Jenny: I really need to pick a fight with a PC one of these days...

    Web Original 
  • Cobra Kai:
    • In the one episode in which he appears in the third season, this, or rather grinding the wrong way, was Brucks' fatal mistake: while he did train and grind off-screen during the second season he's a powerlifter, so while his strength increased his fighting skills didn't. Thus when during tryouts for Kreese's new crew he expects to be able to get a lightning-fast victory over anyone that dares challenge him, his former victim Hawk, who has trained in Cobra Kai Karate the entire time, answers the challenge and mashes him to a pulp in a No-Holds-Barred Beatdown.
    • Averted with Kyler, Brucks' fellow bully during season 1: like Brucks he spent his time in season 2 training offscreen, but as he trained in wrestling his fighting skills actually improved, allowing him to pass Kreese's tryouts. He then started training in Cobra Kai, thus improving even further.
  • Played with in Dragon Ball Z Abridged: Similarly like the source material, Dr. Gero actually did bother to improve by using a robotic bug to constantly watch the Z-Warriors, studying all their moves and tactics to prepare himself and Android 19 to fight them. However, he completely missed the part where they went to Namek and has no idea Goku and Vegeta can become Super Saiyans. Goku is winning handily before his heart disease lays him low, then Vegeta steps in and obliterates Android 19.
    Dr. Gero: The %*%$# is Namek?!
  • The Salvation War has a case of this with the demons. Their tactics haven't changed in centuries, believing that humans could never outdo them. The humans proceed to kill entire armies easily. Later, a character points out that the demons' tactics would have been devastating to humans centuries ago, and they never could have won, but now it's demons with tridents versus humans with guns. The creator pointed out that they could probably still have pulled a victory against World War II era armies. The victory had more to do with modern coordination technology, precision artillery, electronic warfare defenses that make their electric attacks a No-Sell, and advanced enough technical knowledge to reverse-engineer portal creation than just having guns and bombs.

    Western Animation 
  • Avatar: The Last Airbender:
    • Prince Zuko defies this magnificently. At the beginning of the first season, he was only a mild threat, but it was shown multiple times that he was continuing to train and attempt to improve in-between each encounter with Team Avatar, and furthermore each encounter with Aang let Zuko learn more about Aang's fighting style and abilities, how to fight against Aang, etc. The result was Zuko's fighting ability gradually increasing every time he encounters Aang and his friends, and Zuko goes from being curb stomped by Aang in the opening episodes to holding his own against Aang in a prolonged fight late in the season. Zuko's powers were briefly stripped once he joins the Gaang in the middle of the third season, and then quickly returned, and if anything became better after he and Aang were taught the true meaning of Firebending and Zuko adjusts to using a new fighting style.
    • Admiral Zhao and Princess Azula play this straight, however:
      • During Zuko's first encounter with Zhao, Zhao lost mainly due to bad luck, his overconfidence, and because Zuko immediately pressed his advantage to the fullest the moment it presented itself. In their final confrontation Zuko defeats Zhao by utilizing the skills & techniques acquired while training under his uncle's tutelage — and he managed to win with greater ease than in their first encounter despite being exhausted and wounded before the fight.
      • When Azula was first introduced to the series, she represented an existential threat to the entire Gaang — Zuko couldn't even touch her, and Aang was at an obvious disadvantage every time they fought each other. In "The Chase", backing Azula into a corner required the efforts of Aang, Katara, Toph, and just a bit of Enemy Mine with Zuko and Iroh helping them. By the end of the second season, although she was still the most dangerous adversary who had shown up to that point, Aang and Katara had a significant advantage against her by working together, and Katara was getting the better of Azula one-on-one before their fight was interrupted. In the third season Zuko fought her evenly on several occasions and by the time of the series finale, Zuko is on the edge of defeating her in a duel and Katara eventually does defeat Azula on her own. Granted, the Sanity Slippage Azula had undergone just prior to the finale was working against her in those last two fights.
    • Word of God says that Fire Lord Ozai makes it a point to avert this trope by constantly training. Apparently, he and Zuko have this in common.
    • When Korra and Kuvira first duel in Sequel Series, Korra has been out of commission for three years after being mercury poisoned and almost permanently crippled at the end of the previous season, and is still wrestling with PTSD from that. She’s just not her normal self physically or mentally and Kuvira handily beats her until Korra goes into the Avatar State. However, by their final showdown, Korra is back on her feet and Kuvira underestimates what she can do when she’s healthy. The two fight on relatively even terms for awhile in the control room of colossus, but Korra has the edge in the fight before it's interrupted by the explosion that destroys the colossus.
  • Ben 10:
  • In Danny Phantom, Danny's arch-enemy, Vlad Masters/Plasmius, is another half-ghost who has spent the better part of twenty years developing his powers before Danny and he ever come face-to-face. However, Vlad is never shown developing any new powers or skills beyond what he showed off in his debut where Danny gained various new powers as the series continued, with the result that where Danny had to blackmail him to back off in their first encounter, each subsequent clash was more and more in Danny's favour.
  • In Jurassic World: Camp Cretaceous, the main threat faced by the campers in season 1 is Toro, a Carnotaurus who ends up pursuing the campers multiple times throughout the season. Though nowhere as big or tough as the T-Rex or as smart as a Raptor, he's a dangerous large carnivore and a real threat to the group of inexperienced teens, with them barely managing to fight him off at the end of the season by working together. By season 3, Ben, the smallest and least confident member of the group, has spent so much time surviving in the jungle that he's able to fight Toro one-on-one with a spear and match blows with him; his Ankylosaurus friend Bumpy (who's undergone a significant growth spurt from a baby to a large juvenile) can do the same. Working together, they soundly thrash Toro to the point he disappears from the story entirely. As for the rest of the campers, they've moved on to dealing with much greater threats, particularly the E-750, a genetically engineered hybrid on the same level of threat as the Indominus Rex or Indoraptor.
  • Averted in the episode "A Hero's Fate" in OK K.O.! Let's Be Heroes. Hero spent several years level grinding in order to prepare for his final encounter with Galgarion, but when he finally gets around to face him, he discovers Galgarion had also done some Level Grinding himself while waiting: not because of strategy or anything, but because he literally had nothing else to do.
    Galgarion: I can't actually move from this spot.
  • In Redakai, the Hiverax E-Teens are the first E-Teens to consistently give Team Stax a run for their money. Throughout the first half of Season 2, Team Stax has only scored one victory against them, and it's revealed they lost on purpose to distract them from finding out that Lokar survived and that they were working for him. However, in the match right after that one, Team Stax learns their weakness, while the Hiverax doesn't learn anything new and are defeated in all upcoming matches.
  • In the Grand Finale of Samurai Jack, Aku himself, or rather the past version of him, is a victim of this, but it's heavily justified. While the time passed is only a few seconds to him, Jack has had fifty years to hone his skills due to being stranded in the future, not to mention past Aku is still heavily worn down from his battle with past Jack. Aku is crushed quickly.
  • The Spectacular Spider-Man: While he's undoubtedly an Adaptational Badass, keeps himself really fit, and is easily one of the more imposing/competent villains of the show, Tombstone eventually gets hit with this. In the first season, he makes his appearance handing Spider-Man a nasty defeat with minimal effort. By the time he and Spider-Man have their rematch in the second season, Peter had gotten much more experience fighting dangerous superpowered villains while Tombstone didn't go through as many grueling battles and was struggling against Dr. Octopus previously. In their second battle, Spider-Man solidly manages to defeat Tombstone and has him arrested.
  • Star Wars Rebels: Darth Maul never really improved his combat skills over the years. Obi-wan Kenobi went through the grinder of the Clone Wars in addition to his normal training but gained maturity and wisdom in the 30 years since their first encounter while Maul has descended into insanity. Then Maul spends days wandering in the desert, exhausting himself. Their climactic duel is three moves: Obi-wan blocks him twice and kills him with a single stroke. The last move he tries is also the move he used to kill Qui-Gon, which Obi-Wan effortlessly defeats. Also justified, as Obi-wan has since become one of the most experienced experts of the single most defensive lightsaber style.
  • Steven Universe:
    • The Diamonds never train with their powers, and thus despite being rulers of all of Homeworld for several millennia they never actually improve at all. This is especially true for White Diamond, who sees herself as the perfect being with no need to change. Because of this, she remained a Static Character and encouraged, even enforced, the rest of Gem kind to do the same with their determined caste system. Rebecca Sugar confirms this is why Steven ultimately managed to outclass her. He has been growing and changing his whole life, developing his powers and nurturing them to their full potential, showing that even the weakest of the Diamonds powers could eventually outmatch the strongest.
    • When Steven first faced Eyeball and Aquamarine, he was still young and inexperienced with his powers and thus struggled to put up any kind of a fight against them. When they make their return in Steven Universe: Future, he has already had two years' worth of experience and training to grow stronger, while the two of them have remained relatively the same. After they make him mad he easily curb-stomps them both at the same time. Even when they fuse together to get stronger, the most their attacks do is just leave him very annoyed, then the rest of the Crystal Gems arrive to "save" him.
    • However, there’s a bit of an inversion on another front. While Homeworld has been developing technology that eventually outclasses the Crystal Gem’s capabilities, like the Hand Ship or Aquamarine’s Wand, the Crystal Gems chose not to make advances or share their knowledge with humanity. If they didn’t have a diamond on their side, they would’ve easily lost at the end of Season 1.
  • Evident in Teen Titans with the H.I.V.E. Five. In their first appearance, each of the Five is strong enough to nearly defeat a Titan. However, while the heroes continue to train and develop their powers, tactics, and teamwork, the Five spend more time bickering among themselves than anything else and never manage to progress any further to the point where they're a minor threat at best. The only exception is Jinx, and that's because she's the only one of the Five who's completely serious about someday being a great super-villain before her Heel–Face Turn.
  • Cedric in W.I.T.C.H. has supernatural powers that put him roughly at the same level as the heroines, a nasty Scaled Up form, and a lot more experience than his opponents. Unfortunately for him, said heroines start out inexperienced but quickly become much more proficient with their powers, while he never seems to learn any new tricks. By the midpoint of the first season, he's only a threat if he's brought a lot of mooks with him.
  • In her debut, Diaspro from Winx Club was powerful enough to rival (and even fend off sometimes) Bloom, the bearer of the most powerful magic in the universe. And that was at a point when Bloom was no longer a novice fairy and could hold her own for a while against the much more experimented Trix witches. Unfortunately for Diaspro, she never got past the basic fairy transformation while Bloom and the rest of the Winx level-grinded a new transformation each season. When Diaspro and Bloom faced each other again, in season six, it was only because of Bloom's severely weakened state due to gifting her friends with the Dragon's Flame that Diaspro was able to defeat her. And it wasn't even a Curb-Stomp Battle. So it's pretty much implied that Bloom would sweep the floor with Diaspro at least as early as season three which was when Diaspro started to use underhanded tactics to deal her revenge on Bloom.
  • Xiaolin Showdown:
    • The Big Bad, Jack Spicer. In the first season, he's a credible threat, but as the monks gain new powers Jack continues using the same tactics and resources he used in season one.
    • In his first apperance, Cyclops defeats the heroes in three Curb Stomp Battles, and though Omi defeats him the fourth time, it was a very close call, due in part to Omi being shrunk. In his next apperance, Raimundo and Clay are the ones curb stomping him in seconds. Seems the monks have been honing their skills while Cyclops has learned absolutely nothing.
    • To a lesser extent, Mala Mala Jong. In his first appearance, he takes out all the experienced monks at the temple and is considered a real threat, possibly the end of the world. He almost defeats the main characters, and only loses because Omi managed to retrieve the Golden Tiger Claws and steal his power source - The Heart of Jong. In his second appearance, he's split into The Fearsome Four via the Ring of the Nine Dragon. While he does defeat the warriors the first time, it's only because Omi's cockiness was taken to an extreme (for a single episode, in fact), and the other warriors weren't aware of how their strength could be used to their advantage. In the next fight, the warriors easily take down the Fearsome Four, barely even using their wagered Shen Gong Wu, and not even going after the Heart of Jong or the Ring of the Nine Dragons. When they fought him as a single entity, the warriors hadn't really mastered their elemental powers at all. Now, thanks to this and learning how to use them, four Mala Mala Jongs are no match for them.

    Real Life 
  • Possible in the case of exams that can be taken more than once. If you didn't study the first time, you may not get even half the score needed to earn a passing grade. Study enough after that, and the knowledge you learned may come as second nature and may definitely lead to a curb stomp, given the questions remain the same.
  • Subjects where new knowledge continues to directly build on previous knowledge, such as math or music. Maybe now you struggle to do basic algebra or memorize your scales, but if you keep at it, those things become second nature to the point you may wonder how they were ever a problem for you.