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I'm not so sure about the "Not having to be in a game" part - but all it requires is a total of two hours in a game. Whether that's 2 in one game, or 1 hour each in two games, or even one hundred and twenty one-minute games, it all gets counted. There's no limit with regard to how long you have to do this in, so long as the char doesn't hit the 10-day expiry date.