Perhaps that's because its users tend to be rather predictable; I'd be more scared of Smeargle if I didn't instantly know upon seeing it that it would come out first and use Dark Void on the first turn. You could probably make opponents stumble by putting it in the third slot, or even not picking it at all. You could also use support moves like Fake Out, Taunt or Rage Powder to mess up the opponent's counter, though none of those will work against every sleep counter. Basically, Dark Void is very effective if the opponent doesn't counter it, but there's no surefire way to keep them from doing so.
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