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In 2269, while engaging the Romulans in battle, the Vendorian pretending to be Carter Winston damaged the deflectors of the USS Enterprise. Kirk compared the resulting vulnerability of the ship to be as if they were just a clay pigeon to the Romulans. (TAS: "The Survivor")
In 2374, Rafin quoted Namon by saying "It is one matter to fire at clay marks, but much another to nullify the nemesis." He meant that shooting targets was very different from killing individuals. (VOY: "Nemesis")