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He may still hold out energy-wise.
Just like in the NFL--the most recent CBA codified harsh penalties for players who hold out, so players began "holding in." Attending training camp (so, not classified as hold outs) but not participating.
It'll be quite interesting if Simmons executes that strategy--showing up, but basically not participating. I don't know what that would look like once games start, but I'm here for it.