 Arguments against contingent and indeterminate identities appeal to Leibniz's Law. Seen as a principle about the transmission of properties across identity Leibniz's Law has rarely been challenged. Still, it has been challenged. One interesting challenge is brought by Benjamin Schnieder in Schnieder 2006. Similarly, Evans' argument has been challenged from a number of directions. A recent challenger is Elizabeth Barnes who in Barnes 2009 invokes counterpart theory to defuse it.