Writing Samples © 2009 - 2011 Erika Abner Original: The following cases may be helpful in advancing an argument for the reduction of damages based on a contingency. Revised: These cases support our argument to reduce damages based on a contingency. Original: The analysis in Boyd v. International Utility Structures Inc. is illustrative of the approach taken by courts to hybrid lending transactions containing features of both debt and equity. Revised: Boyd illustrates the courts approach to hybrid (debt and equity) lending transactions.