User blog comment:Skeith9/Heroic Spirits Speculation/@comment-24754018-20140730213737/@comment-5739199-20140731022730

lol, technically, Nine Lives is just a bunch of attacks. The "True Nine Lives" is the bow used by Gil in Fate/kaleid liner, and Heracles just used his skills in sword and lance to port the same effect using a sword or lance.

but again, Noble Phantasms are the crystalised form of their legends, or something like that, so technically everything counts. The only reason Tsubame Gaeshi doesn't count it's probably because Kojirou doesn't exist.