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A Grizzly because they can't climb, but they can bring the tree down with you in it or swing the tree back and forth until you fall out.

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Depends on tree size but no fucking way a grizzly is swinging a tree fast enough to knock me out of it

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A common misconception is that grizzly bears, unlike black bears, cannot climb trees. While its long claws make climbing more difficult for a grizzly than for a black bear, a grizzly can get to you in a tree – it will more likely, however, be able to reach you before you reach the tree.

http://www.fws.gov/mountain-prairie/species/mammals/grizzly/misunderstood_bear.pdf