After the close of discovery in a complex commercial dispute, Spotswood Sansom & Sansbury LLC was hired to develop summary judgment theories for a defendant. Spotswood attorneys developed a preemption theory, which had not been asserted in the defendant’s answer. Spotswood attorneys persuaded the court to allow the answer to be amended and, using an obscure procedure, convinced the court to dismiss five of the six counts asserted by the plaintiffs as well as the claim for punitive damages. We are creative lawyers who are not afraid to engineer new approaches to each case. We think outside the box and look beyond the accepted status quo.