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#3 CM Punk vs. Jeff Hardy, Summerslam 2009
In 2009, WWE made the foolhardy decision to reinvigorate their PPV schedule by naming each of their events after a match stipulation and not something cool like No Way Out or Armageddon. You have to understand this was the nadir of the PG Era in WWE.
As such, despite a showstopping feud conclusion between Jeff Hardy and CM Punk at Summerslam, the contest was somewhat aptly contested in a TLC match rather than Hell in a Cell. Sure, Jeff Hardy is the innovator of the stipulation but it wasn't anything new to see from the two individuals. Instead, Hell in a Cell would have fulfilled Jeff's dreams to contest in it a full decade earlier while also blown it off in epic proportions.
Secondly, it would make characteristic sense for the Undertaker to attack a victorious Punk from within Satan's structure much like he did at Summerslam. Instead, because the PPV was about to debut in two months and they needed to live up to the moniker with three unnecessary bouts inside the once vaunted cage.
