Ho Te-lai, born ten years after Liu, resisted the formulaic paintings of the competitions and for the greater part of his life shut himself up in Japan, where he joined the Shinkozo-Sha (the "New Structure Society") school characterized by freedom and unrestricted direction. He remained faithful to his own thoughts, and to his personal creative device of inserting words into his paintings.
而晚劉錦堂十年出生的何德來因為抗拒比賽的形式化，大半生閉門自居於日本，加入以自由、無定為宗旨的「新構造社」畫會，以忠於自己內心思考為先、加上文字入畫的個人方式創作。