|Review 5 or more user-created content items in Community Creations.|
Just review 5 upload on Community Creations by different people. It can also be an empty comment you just need to rate an item. Go to Xbox Live>Community Creations>Download. Select an item, select View and then select "Send Review". The cheevo should pop after you have made 5 reviews.
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User Score is based on 139 user ratings.