ana sounds serious about suing. I think we should talk about how we could defend ourselves if she actually filed a claim. Dane Imhoff, do we have any other defenses? Dane Imhoff We could assert the clean hands defense. Mike The "clean hands" doctrine might come into play if we were suing Ms. Aspen for breach of contract. We would have to show that we weren't at fault and didn't cause the breach. But I don't think that applies here. However, I do remember something about substantial performance but I'm fuzzy on the details. Could you explain that a little bit more, Dane Imhoff? Dinna imhunff You made a good faith effort to perform, any shortcoming was unintentional, and you didn't impact the value or the essential terms of the agreement. You made a good faith effort to perform all of your obligations and even large or "material" deviations from your contract obligations are OK if they were unintentional.