Fall of Cair Andros (PLTR-124S) - Tales of Middle-earth Promos Foil

Whenever a creature an opponent controls is dealt excess noncombat damage, amass Orcs X, where X is that excess damage. (Put X +1/+1 counters on an Army you control. It's also an Orc. If you don't control an Army, create a 0/0 black Orc Army creature token first.)
: Fall of Cair Andros deals 7 damage to target creature.