User blog comment:Xilinoc/Ch. 610 - Mausoleum of Skulls/@comment-9096222-20141223172751/@comment-5693502-20141224055706

Ichigo vs Kenpachi still feels like a draw to me. They both landed grievous blows and Ichigo was the one who passed out first so technically speaking, even though Kenpachi conceded defeat, Ichigo is the one who lost (but I'll take a draw).

Still though, there's no way Kenpachi could do anything after fighting Gremmy (full reiatsu or not).