Breast implants can be placed through incisions made under the breast in the crease, around the areola, in the armpit, or through the belly button. I prefer the incision in the breast crease. It is impossible to see unless the woman is lying down nude.
If done properly, even when she is naked the incision should be hard to see. The operation is simplest in this location. Simple is good for the doctor, and good for the patient.
Simple translates to a lower chance of complications. Specifically, this location is associated with the lowest chance of a misplaced implant.
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