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I think building up a heel to go against Cena means that they have to be believably able to beat Cena. The most compelling drama is when the fan genuinely has no idea whats going to happen.
Of course, this doesn't mean that the heel would be as good as Cena, as McMahon could never beat the shit out of Austin. You would just need someone who due to his ring work/ his sway or power in the company/his smarts/his incredible heelishness is someone who the fans believe could actually beat Cena. Really, the WWE hasn't done that, and to an extent, its hard to do that with Cena's character.
This is why Nexus works so well against Cena though. While one of them is no match, a pack of thugs going after Cena is believable, and we've seen Cena get the shit kicked out of him AND cost him his title (twice). IMO, Cena has been getting bigger pops lately, and thats because he's going against a formidable foe.
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