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It's rather hard to tell, but the Dalek in the center has a missing panel that reveals some kind of little blob inside. Thus, "naked."
The title, by the way, was originally just going to be "Nightmares," but since narly every Doctor Who episode that's ever featured the Daleks (usually as "surprise" villains) has been named "(___blank___) of the Daleks." If BBC can ruin the surprise every single time, why can't we?
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