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I think it'd somehow cheapen the cup if it wasn't given to an NHL team, even if they didn't play. Juniors are all the rage in Canada, but they have their only tournament (Memorial cup) just as the AHL has theirs (Calder Cup). You can't give the cup out to a league who already has their own prize, just because the NHL isn't play.
And a tournament is not the answer. The AHL's would own the Juniors, because they are still very raw.
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