An allusion to the policy underlying the rule may help apply the rule to these facts. Applying these standards to the facts given, we look at the complaint Katz has served. This complaint does not have a lot of details. It does not give specifics about the nature of the breach. A court taking a liberal approach would probably find this complaint sufficient, because it seems to give the defendant enough to proceed to the discovery stage.
Some courts take a stricter approach to pleading.
A court taking a stricter approach might strike this complaint down. The strict approach, however, is generally not applied in common areas of litigation like contract claims, and has now been rejected in other areas, such as civil rights litigation, where it has sometimes been applied in the past. Therefore, I would not expect the court to apply such a strict approach here. If there are alternate possibilities for your analysis, they should be applied. You must use your judgment about how far afield you should go in discussing other possible analyses.