Scott,
The thing is most photos authenticated by PSA are not slabbed. PSA only slabs photos that are close to 8x10 in size. If the photos are smaller or larger than this size, they are not slabbed. You just the exact same photo you sent in, but with a sticker on the back matching it to the LOA. So, just ballparking it, I would say that less than 10% of photos from PSA are slabbed, so most photos are never hidden in plastic.
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