James Kaufman purchased 11 heifers from Peter Van Santen. Van Santen provided in their agreement that the cows had "no mastitis." Mastitis is an inflammation of the milk-producing tissue in the udder that can result in infection and reduction of milk production. Shortly after taking delivery, Kaufman discovered mastitis in the cows. One had to be killed and the remainder of Kaufman's herd became infected. He lost $30,000 because of decreased milk production and spent nearly $600 in vet bills. Can Kaufman recover from Van Santen? If so, on what theories?