Considering that unlocks in this game are solely cosmetic, as they want individual skill and seamanship to decide conflicts, not arbitrary numbers and levels, isn't having cosmetic only Microtransactions pay to win? in a game where the only unlocks are cosmetic?
EDIT: This thread is NOT about using real currency to gain a combat advantage over an opponent. This is a discussion on what Winning is in SoT and how Microtransactions effect that journey.

