Technology
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buying a case actually exacerbates the scratching issue, as any small piece that gets into the case scratches it over time, hence experiences with Essential PH-1s. its just a symptom of titanium.
as a material, titanium is actually softer than some aluminum based alloys, so its softness allows for some dust, which have a higher hardness than it, to scratch it up. a common material that would scratch it up would be a grain of sand, and if caught inside the case, would do damage overtime.