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No. If that was the case, than pretty much any and all games with DLC are "pay to win". This is "Pay to get the DLC, which brings back weapons". Same as a lot of other games have done.
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Your paying money for a op gun. They are forcing people to pay to win. After then gun drops everyone will say gally or get out. So yes pay to play and pay to win.
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Except that in this case, everyone who has the DLC will get GHorn. And having the DLC will be a requirement for having the new raid, so you're going to have to get the DLC to keep moving forward in the game anyhow. It's like any DLC. You want more game, buy the DLC. Fallout, CoD, Battlefield, etc.