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Yep.
99% of the time for me it was the builder.
I have had multiple wheelsets that were incredibly similar built by different people, the wheels built by the expert builder were bombproof and the wheels built by the LBS guy who kind of knew what he was doing had issues.
I would expect this is completely independent of materials. If the carbon wheels are not built correctly good luck. Maybe shorter spokes and stronger rims makes them more tolerant of build mistakes though.
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