Not all laminations peel off in perfect strips, some of them are ragged and fragmented such as this one. Circulation wear can mask the metal grain exposed by the lamination and make it appear to be PMD.
I've seen them like that before. If it were devices from another coin, how would the design transfer to the head and the field without making a strong impression on the tops of the devices? The planchet peeled away some of the lamination.
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