Kramer (2009) reports a case study of the cognitive-behavioral treatment (CBT) of Posttraumatic Stress Disorder that involved individualizing the therapy to the distinctive aspects of the client’s personality and life circumstances. This individualization process was facilitated by Grawe and Caspar’s "Plan Analysis," which is a model for assessment and treatment planning. In this commentary I discuss the general issues raised by Kramer’s deviation from a strict manualized CBT approach in this case. I also comment on the value of Kramer’s case as a contribution to the Plan Analysis approach by concretizing this model within a detailed, systematic case study.