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Simple answer: There is no such thing as "non-fully walled territory". So far as the upper left is concerned, black has exactly two points: D10 and F10. All the rest is not territory, because it's not enclosed. Sure, it's all potential territory, but it only becomes actual territory when black takes that critical L11 point to actually enclose it. So if ...


This isn't really a finished game. If both players passed, then all of the points around E13 would count as dame just like the ones around H8, and wouldn't be territory for Black. This wouldn't happen in a serious game, so in a beginners' game, you would notice the problem during the scoring and probably just fix it.

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