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yep there is a high and low intensity palette. the two main are the high intensity 0 and 1, with 0 and 1 being the darker versions

The full CGA color palette is not allowed

So I would have thought FFAAFF was valid.

I think it is the spirit of CGA palette that needs to be kept. So you have a 'pink/magenta' a darker version of that for the other palette, etc