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Based off of Marketplace.tf prices. The hat is worth more based off of it's effect compared to the others in it's set but since it's heavy, 13 seems reasonable.
Using 'similar effects' and sellers is not the way to make a suggestion.
You need proven sales, not speculative prices based on other items and average unusual / effect prices.
Please take a look at the Unusual suggestion rules, found here:
https://forums.backpack.tf/topic/6033-rules-for-unusual-price-suggestions/
If you really want to get into suggesting, I recommend you look at the above rules and join the backpack.tf discord. The users there can help you get started!
http://backpack.tf/rules
There's no "seems" when voting, you need proof of SALES, not just opinions.