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Originally Posted by Shay
Are there any special requirements for Kabuto's Zombie no jutsu or can he just resurrect anyone who's dead? For example, could he resurrect the 1st Hokage?
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The biggest limitation is that anyone sealed away can not be summoned again unless the seal is broken.
In the case of the 1st Hokage he is sealed in the death god (when Orochimaru summoned him in the fight against the third hokage) and is therefore unsummonable because the death god seal can not be broken (as far as we know).
Other then that he needs dna and a living body/person.
EDIT: The 4th sealed half of the kyuubi inside him using the death god seal. The other half was sealed into Naruto (I don't know if the Kyuubi in Naruto has all his chakra restored or if he only has half).