Sand-attack. Never has a move been so frustrating when it is getting used on you but so useless when you are the one using it -_-
And Duke's final form special attack in Tales of Vesperia. He uses everyone's Mystic Artes and pretty much heals all his health to the start. The only way I found to beat it was hope Yuri's combo doesn't break >_>
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FF7 and the Underwater Materia. Its Aire Tam attack was instant death.
Even the Ruby Materia was a pain.
You mean the Emerald and Ruby Weapons.
Aire Tam (Materia spelled backwards) Storm does damage directly proportional to how many Materia you have equipped.
As for Ruby, start the battle with a single character alive and have them use Phoenix at the start of the battle.
I'm not sure what the most annoying attack I've encountered would be, but a thief in Disgaea 2 would be the cheapest by far (guaranteed to hit sleep/ poison attacks means a naked level 20 thief can kill a level 9999 Divine Majin).
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Nancy in Tekken 6, every time I would come close to killing Nancy it cuts a hole in the floor and you would have to start all over again to get another chance at fighting it, and I really wanted to get the Play Station trophy you get for beating it. I think may unlock something else as well but I can't remember.
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Pretty much any attack where the enemy heals itself is annoying. Also, when the enemy spawns more enemies or makes itself invincible for a turn. All it's doing is making the battle drag on even longer.