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The combat loop has an attack-startup penalty for first 2 rounds, largest for foot infanty, to model the fact that attackers need to close the distance vs defender firing from prepared positions. This interacts weirdly with the counter-attack mechanic though, in a way that benefits the infantry attackers and to the detriment of infantry defender, on the first round of combat.

In the example below, "MG V" and "Foot V" are attacking models, "Troopers IV" defending model.
Screenshots from first round of combat.

The regular attacks make sense -
"MG V(16)" attacks "Troopers IV(118)" with a -75% startup penalty,
"Troopers IV(118)" later attacks "Foot V(92)" without startup penalty (being the defender).

The counter-attacks dont -
"Foot V(92)" counter-attacks with -50% penalty, which is a actually a buff instead of a "weaker attack", since their regular attack on first round would have had a -75% startup penalty.
"Troopers IV(118)" counter-attacks with a -75% startup penalty, which is weird (being the defender) and is actually weaker than the -50% penalty for counter attack.

I'd think the attacker would have both the startup *and* the counter-attack penalties, the defender - only the counter-attack.

Here's another weird variation on this, same combat, different unit.

"GI's V" is another defending model, "Foot V" attacking, first round of combat.

Here, subunit "GI's V(131)" is attacked five times.

First three counter-attacks have the same -75% startup penalty (which doesnt make sense to me).
Only starting on fourth counter-attack there is *additional* counter-attack penalty of -34% (and attacking "Foot V(34)" had by this point a max attacked penalty of -33%.)
Fifth counter-attack has the additional and stronger counter-attack penalty of -56% (the attacking "Foot V(94)" had a -50% max attacked penalty).

Also - I thought infantry has "max attacked" of 2, why attacks on "GI's V" are debuffed from the fourth, not the third attack?

1. the defender uses the startup penalty for counter attacks and the attacker for attacks. revision of this in future is not impossible. i'll give it some thought.

2. counter attack penalty goes up if a lot of counter attacks are made in the same combat round