Yes, it does. I found 51 hits on toughnessRange in the code - though probably not all of them are in scenes.
Some examples:
Drifa sex scene -> At the end, you either become exhausted or listen to her and kiss her.
Thalia sex scene -> She tackles/hugs you - the air gets knocked out of you, or you manage to outmaneuver her.
Obviously, it all depends on the author - some will use it more, some less. I’d also point out that the majority of these checks - not just toughness - aren’t very noticeable unless you have a lot of characters or inspect the code directly.
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