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Lots ultimate body-builders really haven't attached to important amount of muscle on their time well versed in the gym, but they have put on some inches on their arms. The explanation why many gymnasium rats can get bigger biceps is because, extremely localized muscle stimulation ( hypertrophy ) can happen if there's enough volume there. Just look at the forearms of arm fighters, or the calves on soccer fanatics. It can happen very little a limit to what distance you can go with skyrocketing size this way.