More diversity to the FotR Sealed League? I'm all for it!
You left Merry out apparently; with him the 25 cards count would be fulfilled. But Gemp sealed decks are 30-30 cards, so that directive should be changed anyway. And considering how weak the original Deluxe Starter is (had it IRL some 18 or 17 years ago), that's good news.
The FP side will weep and bleed past site 5 with their low base strength, so I'd add a third Boromir, an
Armor (imperative vs Uruks) and a fourth
Hobbit Sword to help them survive. That leaves us with 2 empty card slots... 1x
TABA and 1x
ATFNBS look suitable for the role. And then there's the problem of
Hobbit Party Guest doing nothing without a home 1 Hobbit ally to heal, to which
Rosie Cotton HL is the only non-Rare answer. I'd add 1x Rosie and cut 1x Guest off, that or 2x Rosie and remove all Guests. That's 30 cards, and all useful.
Besides,
Halfling Deftness can be exchanged for
Dagger Strike, considering how costly is to exert mid-skirmish against Uruks.
Your Shadow side looks pretty good, actually. While removing
Blade Tip is pure joy to my eyes, having only 2x
Black Breath will make Lemenya's text too unreliable, so I'd add a third copy for that reason alone (keep in mind that having only 5 non-Rare Nazgul to base your deck on, each one of them must be impactful when hitting the board). Add a 3rd
Morgul Skulker for resourcefulness, a third pump, another sword (either the generic one or
Sword of Minas Morgul), and finally something funny like
the Nine Servants of Sauron or
Morgul Skirmisher to counter Hobbits (
Bounder). That'd be my take.
All that talk about splashing Nazgul cards seems a bit baseless to me: I would never swap a well-rounded starting deck for a weak fellowship that provides
no Premium cards and cannot double move, just because it happens to also pack 1x Nertea + 3x
Black Breath.
My 2 cents.