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I hear that the license plate "screeners" sit around and run the names by each other. If it's "naughty" in nature, it's a thumbs down. I'm guessing "Topless" might raise some eyebrows! Ha!
I checked on the Michigan plate site and XXXFIRE, AND TOPLESS are unavailable. Means either someone already has them or they won't make them. I'm guessing the later.