Basenji: These clever and curious dogs often have a mind of their own and may not always respond to commands.
Afghan Hound: Afghan Hounds have a strong prey drive and may prioritize chasing over following instructions.
Jack Russell Terrier: Highly energetic and intelligent, Jack Russells can be willful and may require consistent training.
Shiba Inu: Known for their independence, Shiba Inus can be aloof and may not always comply with commands.
Borzoi: These elegant dogs have an independent streak and may choose when to listen to commands.
Chow Chow: Chow Chows are loyal but can be stubborn, making them less eager to obey instructions.