Hmmmm good question, I know, bad answer. I have never used an invisible fence, but I wouldn't think a bully would be any harder to teach than any other dog, even though they can be stubborn sometimes. I would not let them out unsupervised though as they do have a high tolerance to pain and if they want out they will ignore the pain. I'm sure someone who has used this before will be along shortly. Plus in case I have not said it before, welcome to the site.