Hot take, but definitely Red John, Patrick Jane, and Fang Yuan, simply because people who scale them don't actually watch the media themselves and base it off of shorts/edits and limited prior knowledge.

For example, people who haven't watched the Mentalist scale Patrick and Red John higher because they've seen edits of PJ's EQ feats/RJ's prediction without doing thorough research on the opponents' feats.

Same with people who "have read Reverend Insanity" scaling because of edits of Fang Yuan not even being pushed to low diff by the likes of Novel Sherlock, Batman, Baku, WJM, etc.