Transformational analogy is currently more widely employed than derivational analogy in CBR applications, even though the latter has significant advantages over the former. The main reason for the reluctance to use derivational analogy is the complexity of representation. Other factors include issues related to retrieval and difficulties in system validation. Means of addressing these issues are described in this paper. Unique opportunities offered by the approach are illustrated with examples. © Springer-Verlag Berlin Heidelberg 2006.