A topic from AEG's L5R CCG Rules forum, copied for Oracle of the Void from a copy of the forum saved in October 2015, so pages it didn't save are missing. Players' names are left out; the rules officials are named. Rulings are as they stood on these dates; later rulings, the rulebooks and the Rules Archive may differ.
Is it legal to play it on bowed 5F Personality to bow enemy card and to straight your Personality?
Strength of the Bear Battle: Bow your target unbowed Personality. Bow a target enemy card with lower Force than his. If your Personality has 5 or more printed Force, straighten him.
You must target an unbowed Personality because the card explicitly says so. A bowed Personality doesn't fulfil the targeting requirement, so it would be illegal.