question: Draft a motion for summary judgment, ensuring that the main arguments are presented in a clear and compelling manner. Provide this draft using JSON format, in English and all capital letters.
answer: ```json
  {
    "motion_for_summary_judgment": {
      "title": "DEFENDANT'S MOTION FOR SUMMARY JUDGMENT",
      "introduction": "DEFENDANT, BY AND THROUGH ITS UNDERSIGNED COUNSEL, HEREBY MOVES THIS HONORABLE COURT FOR SUMMARY JUDGMENT IN ITS FAVOR PURSUANT TO RULE 56 OF THE FEDERAL RULES OF CIVIL PROCEDURE. AS THERE ARE NO GENUINE ISSUES OF MATERIAL FACT AND THE DEFENDANT IS ENTITLED TO JUDGMENT AS A MATTER OF LAW, THIS MOTION SHOULD BE GRANTED.",
      "background": "PLAINTIFF FILED THIS ACTION ALLEGING BREACH OF CONTRACT AND NEGLIGENCE. HOWEVER, THE UNDISPUTED FACTS SHOW THAT DEFENDANT FULFILLED ALL CONTRACTUAL OBLIGATIONS AND EXERCISED DUE CARE IN ALL DEALINGS WITH THE PLAINTIFF.",
      "argument": {
        "point_1": "DEFENDANT DID NOT BREACH THE CONTRACT. THE CONTRACTUAL TERMS WERE CLEARLY DEFINED AND DEFENDANT PERFORMED ALL OBLIGATIONS AS AGREED. PLAINTIFF HAS FAILED TO PROVIDE EVIDENCE OF ANY SPECIFIC TERMS THAT WERE BREACHED.",
        "point_2": "NO NEGLIGENCE CAN BE ATTRIBUTED TO THE DEFENDANT. THE DEFENDANT EXERCISED REASONABLE CARE AND DILIGENCE IN ALL INTERACTIONS WITH THE PLAINTIFF. PLAINTIFF HAS NOT PRESENTED ANY EVIDENCE OF NEGLIGENCE OR DEVIATION FROM STANDARD PRACTICES.",
        "point_3": "PLAINTIFF SUFFERED NO DAMAGES CAUSED BY DEFENDANT. EVEN IF THERE WERE A BREACH OR NEGLIGENCE, WHICH IS DENIED, PLAINTIFF HAS NOT DEMONSTRATED ANY ACTUAL DAMAGES PROXIMATELY CAUSED BY DEFENDANT'S ACTIONS."
      },
      "conclusion": "FOR THE FOREGOING REASONS, DEFENDANT RESPECTFULLY REQUESTS THAT THIS COURT GRANT ITS MOTION FOR SUMMARY JUDGMENT AND DISMISS PLAINTIFF'S CLAIMS WITH PREJUDICE.",
      "signature": "RESPECTFULLY SUBMITTED, [ATTORNEY NAME], [LAW FIRM NAME], [ADDRESS], [PHONE NUMBER], [EMAIL]"
    }
  }
  ```