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Disagree completely. The level of the elite teams has undoubtedly risen even relative to say 5-6 years ago. Munster won ***les with mediocre props and a backline full of average players like Ian Dowling, Anthony Horgan and Denis Hurley, Wasps won with the likes of Tom French, Richard Birkett, Tom Voyce, Mark van Gisbergen. There was a clear marked difference between the quality of the squads back then compared to international teams. More recently the likes of Joe Schmidt's Leinster, Toulon or Clermont have had squads complete from 1-15 and with quality superior to many international sides (Schmidt's Leinster would have beaten Ireland, Toulon or Clermont would easily beat France). European domestic rugby has far more quality players from across the globe than it did even 4-5 years ago.
Ok, I haven't explained myself well. I think 2005 is a good year to start with due to it being a time when rugby began to change into the sport we have today. Relative to all the other teams at the time, the competitiveness if the competition and due to club sides not having anywhere near the resources they have today Ibthink a team like '06 Munster is better than Toulon. It's a bit of an impossible exercise but if you don't have factors like it it becomes impossible to compare sides from different years.
If you forget that they have done three in a row, again a stupid exercise due to the magnitude of the achievement, there individual cup wins were somewhat unremarkable considering in all their semi finals and finals they played a total of four teams. Of these four teams one was a defending domestic champion, Leinster who were 5th in the pro12 when they met and they needed a gift to win the match, one was a rather shambolic Munster side, they played Saracens twice and twice Saracens proved they are nothing without a dominant pack and Clermont twice, yesterday when again they were gifted a win and 2013 when it was generally agreed that they were outplayed over 80mims and nicked it after Clermont bottled yet again. They had an easy route and although they did have to be good enough to take advantage of this I think the fact that they never really faced monumental challenges like beating bloodgate, the Saints to the second half in '11, Clermont in Bordeaux (spot the Leinster fan!), Biarittz' early onslaught in '06, Munster in Lansedowne in '05 or those Toulouse sides in '07 and '08 they will alwaysbe remembered for the threepeat, to use an awful Americanism, rather than any specific defining moment which sports fans really love.
They're like Nick Faldo compared to Seve Ballesteros in terms of majors and competition wins Faldo has won more but the manner of his victories and the way he achieved them mean that Seve will always be remembered as the better of the two. Of course this is all romantic bull**** but unless Toulon go four in a row, which won't happen they're undergoing too much change next year, they're still in the same legue as Leinster and Toulouse in terms of GOAT in my opinion, whereas had they won from '11-13 for example they'd be light years ahead.
TL;DR Factors have to be taken into account when comparing sides 5+ years apart and Toulon were in the right place at the right time, facing little adversary on their way to three in a row.