Actually I can. Predator doesn't have an overhead starter therefore by your logic he is a mid-low tier. Kung Lao SUPER low tier because he doesn't have a low starter and he has a very punishable teleport.
Tanya SUPER DUPER low tier because she doesn't have any overhead starters unless you are counting the 50 frames overhead that nobody uses. Tremor is of course also low tier because he doesn't have an overhead starter. ANY character that doesn't have both overhead and low starters is an instant low tier by this logic.
But what you don't seem to get is that this game is not just 50/50s, it's much MUCH more. Tanya makes up for the lack of any real 50/50 with the ability to pressure in on variation and the ability to zone(which she can't do as good anymore).
This game like any other fighting game is about mind games as well as mixups NOT 50/50s. Which people seem to get confused by. 50/50s are not mixups, they are part of mixups.
Take @
Pig Of The Hut for example. He showed people that 50/50s are not really mixups. By using Kenshi and being able to open opponents up even though he doesn't have an overhead starter.
There is something called THROW which every character has got and therefore every character has a mixup. Will he run and grab me? Or will he run and as I let go of block expecting a throw he goes for a special move that goes into a 30% or more combo? That's a mixup.
Do characters benefit from having both low and overhead? Sure 100% they do but that does not make them top tier. Takeda has a low and overhead starters, is he top tier? You see what I'm trying to say. 50/50s doesn't make a character top tier just like Kitana is top tier not because of 50/50s but because of what she brings to the table in terms of really safe strings/high METERLESS damage/super duper good armoured moves/mobility/zoning/frame traps.