3-ER for 3 tough status cards. 1ER per tough card is actually crazy.
I won't say it's overpowered, but the only reason it's not overpowered is because of all the crazy stuff other teams can do. This card alone probably won't make Defenders a better tribe for Leadership than Avengers or X-Men. But the ability to produce 1-ER tough cards is still insane and will keep you protected from attacks through the whole game, making it very difficult for the villain to land hits without using piercing damage.