Battle under the trees because (long shot) Galadriel goes into Dol Guldur, showing that she charges into the castle/fort/stronghold. In the others, they're going away from it. As I said, a long shot!
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'But Melkor also was there, and he came to the house of Fëanor, and there he slew Finwë King of the Noldor before his doors, and spilled the first blood in the Blessed Realm; for Finwë alone had not fled from the horror of the Dark.'
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