In video games where you unfairly lose.
For example, games like Battletoads or Ninja Gaiden might be difficult, but you will only lose due to lack of skill. On the other hand, Touhou or a battle with an enemy with SNK boss syndrome are made difficult by unfair means and have a ton of cheap death.
Call of Duty on veteran mode is full of cheap deaths because the enemies infinitely respawn until you get to a certain point, they all have pinpoint aim, and they all have infinite grenades.
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