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So Wreck-Gar gets Bold 1 and Tough 1 while he has a Bold or Tough upgrade. Does that work for upgrades such as Staggering Might and Combat Training, even when they don't actually give him Bold or Tough at the time?

Yes. A " Upgrade" is an upgrade that could give or has an effect if the character has .
For example, Staggering Might could give a character Bold, so it's a Bold upgrade. Conversely, Polarity Gauntlet does not give a character Bold, so it is not a Bold upgrade.
Source: Aequitas (2023-07-05)    【Link to Ruling】
Tags: Wreck-Gar, The Big Cheese! Now With More Cheese!
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