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Well the problem is the freezing. Freezing can sometimes be more detrimental than Paralysis (it's essentially sleep). 20 power like Nuzzle would be fine, but I would definitely put the accuracy on the lower end like Hypnosis.

That would be a little OP, unless the accuracy was significantly lower. I'd say maybe 60% accuracy to match Hypnosis, or as low as 50% if it also does damage.

And give Rock/Ground types a third 4x weakness? No thank you.