Cool subject! I don't know the answer and would like to take a guess before someone answers.
I would assume that terrestrial orchids would need dark seed growth as their seeds would most likely germinate under leaf litter and under other taller plants in the wild.
Epiphytes, I assume should be given adequate light, I'm thinking of a seed that lands on a tree limb and grows in dappled sunlight. Or twig epiphytes that probably get harsh sunny and dry conditions from the beginning.
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All that is gold does not glitter,
Not all those who wander are lost;
The old that is strong does not wither,
Deep roots are not reached by the frost.
-J.R.R. Tolkien, LOTR, Fellowship of the Ring
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