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Michaels is American, Hart Canadian, Hart got screwed out of the title legit, and the Canadian fans will never let it go, whereas Cena isn't Canadian, won't get screwed out the title legit and no-one will care or remember after 2 years.
Plus Jericho is Canadian, so will probably get cheered. Though the Bischoff/Canadian flag on RAW was a nice touch to get the team Jericho boo's going.
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