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Comparable Call Issue

Like many directors, I'm trying to sort through various issues raised by the comparable call rule.  What are the issues where the non-offenders psyche to frustrate the ability of the offenders in making a comparable call?  I'll give you the problem as it arose, but I think it really points back to some corner problems with the comparable call rules.

3rd seat opens 2NT (20-21 balanced)  before anyone else has bid.  I ask if 4th seat wants to accept the bid, and they want to know what happens if they don't.  

I explained that if the bid was not accepted, under rule 31B, the correct 1st seat opener (offender's partner) will make their bid, and if it is pass and 2nd seat passes, 3rd seat will repeat the bid of 2NT, and if not, 3rd seat may make any comparable call in which case things proceed as normally, or if they do not make a comparable call, their partner (1st seat) will pass their next round of bidding.  

So, 1st seat passed.  Then I observed that 2nd seat psyched a 1D bid with 8 points, and 5=2=3=2 shape (5 spades).  This had the intended effect of making a comparable call by third seat impossible.  

In practical reality 3rd seat bid 3nt and made, so I didn't change the score.  

But I'm deeply uneasy about the legal ramifications of the 1D bid.  

(I talked this over with another director and he suggested that X intending to rebid NT might be a comparable call, but I think that is wrong because the intention to rebid NT is not known at the time the double is made, and the double without the rebid doesn't fit any of the three definitions of comparable call.)

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