You know, I questioned this myself. Not for that reason though. 40% bonus armor pen is strictly worse than 35% total armor pen. Frozen Heart+base armor alone is probably like 140. .65x140=91, or 47% physical damage reduction. .6x90+50=104, or 51% physical damage reduction. I just wanted to throw that out there.
That said I think the answer to that question is basically "Holy shit its still an amazing item is there nothing we can do to make this thing not good?" Is it overshadowed by
? As a first build, sure, but Plate doesn't have the raw efficiency of Frozen Heart. Plate can't shut down 2-4 members of a team just by existing. Plate give 0% CDR.