I don't think direct contact is anything that the judiciary cares about... it's force that they judge on... so it doesn't matter if it's primary or secondary contact.
Panthers mainly argued that he didn't go off for a HIA so how could the force be deemed moderate.
Hugo didn't go off for a HIA, so they could easily argue that the force wasn't moderate... this is now part of the precedent
Hugo was also falling, so they can easily argue mitigating factors... definitely falling more than the Cleary tackle.
Everything else is inline with the Cleary precedent.
I don't think they will contest the grading, because the argument for force will be hard just from the optics of it... but the independent Dr didn't pull him from the field... so it's there if they want it... thanks to Ivan