Tough Luck
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Tough Luck is a gold skull. It is the first skull on the third level, Tsavo Highway. As a gold skull, it offers an achievement and 150% bonus on campaign scoring. In return, enemies will have much better luck dodging your grenades, needles, vehicles and plasma bolts.
After emerging from the end of the first shielded tunnel and onto the Tsavo Highway, walk along the edge of the gorge to your left. Jumping carefully down onto the bridge support, walk around the edge of the supports to your left until you reach a stone ledge with this skull.