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I have friend safaris for all of Togepi, Tyrogue, and Riolu, so I went out and caught one of each from those. In all three cases, they ended up with 3 31s instead of the normal 2 that are guaranteed in FS. Assuming they were all configured to have just a 2 guarantee instead of the 3 from their egg group, the odds of ending up with at least 3 anyway are about 12% per trial, and already at three trials that's a 0.17% chance that it holds true all three times, as opposed to only getting them because of a 3 guarantee in the first place. It's not much trouble to get more samples, but how many more would you want?