In Archbishop v. G.F.G. Corp., 1995 WL 604383 (D. Guam App.Div. October 2, 1995), wherein that court was faced with the very same issue with respect to the enforcement of a lease provision for the payment of rent. In that case, the defendant corporation entered into a 99 year lease with the Archbishop of Guam in February, 1989. The lease specified a sum certain to be paid as rent each month for the term of the lease. The defendant failed to pay rent beyond December 1992. An unlawful detainer action was instituted in September, 1994. The defendant's answer included, as a defense, the Archbishop's violation of the above-referenced statute. Defendant filed a motion to dismiss arguing that the Archbishop's lack of possession of a business license during the time at issue barred the relief sought. The lower court denied the defendant's motion and trial on the matter proceeded. During the time period for which he had sought to recover rent, the Archbishop did not have a business license nor did he have a statement of exemption from the Department of Revenue and Taxation; however, the lower court found that the Archbishop substantially complied with the statute by obtaining a certificate of exemption from the Department of Revenue and Taxation in October, 1994. The Appellate Division reversed. The appellate court held that it was consistent with the policy of the statute that all businesses must have either a business license or a statement of exemption issued by the Department of Revenue and Taxation. Id. It also found that the language of the statute is mandatory. Id. Finally, because the acquisition of a statement of exemption was the same as the term "business license", the Archbishop had the burden of proving he had either a business license, or an exemption, at the time of the breach. Id. The Archbishop argued that, pursuant to subsection (f), he had substantially complied with the business license requirement. But the court responded by observing that a substantial compliance determination cannot result in the circumvention of a clear statutory policy. Id. It held that the policy of obtaining a business license or an exemption is at the heart of the statute and that the purpose of the statute would be impaired if a party seeking enforcement of a lease could substantially comply with the statute's provisions by obtaining a license or statement of exemption after the lease obligations have incurred. Id.