No, because you can get rep boosters out of normal crucible / vanguard / hoj packages, so they are attainable without silver...
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Pay to win methods don't exclude items attainable for free in-game. It just means that you can buy items that can give you an advantage over the rest. If you buy a lot of sterling t., you'll have a lot of faction rep boosters, therefore you will always be able to rank up faster than others
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I respectfully disagree, P2W denotes an advantage given to players ONLY for money. Paying for rep boosters through treasures doesn't guarantee you MORE boosters than anyone else. The only thing it basically "guarantees" is that you will get them quicker. And in fact, it probably levels the playing field because someone who plays a ton will get x number of boosters, where as those who buy boosters probably don't have as much time to play...