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This study compares the motivations for using violence and the context in which violence occurs among male and female domestic violence perpetrators. One hundred twenty-five participants in batterer intervention counseling in Los Angeles County, California, were surveyed. The sample was approximately half male and half female. Males and females were found to differ in their motivations for using violence in relationships. Females reported using violence in response to prior abuse, citing revenge and retaliation as a primary motivation. Because treatment approaches are commonly derived from the power and control model, which indicates that violence is used to gain power and control, batterer intervention counseling may not be appropriate for women, who appear more motivated by the desire to maintain personal liberties in a relationship where they have been victimized. Treatment must walk the fine line between addressing victimization issues and holding women accountable for decisions to use violence.