Alright, I can confirm orcs go higher than level 40. For the Bright Lord's Armor you get from barrows in Minas Ithil, I just upgraded it to level 20 after completing the upgrade challenge. Now there's a new challenge for a level 40 upgrade, to which I must recruit a Tank that is level 40 or higher.

So orc levels go MUCH higher this game. I'm betting, if there's a cap in levels, it's at a minimum level 50, maybe even as high as 75 or 99.

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