I did 41 just now in 3-hit-mode ... its not that difficult if you got it alle out.
Just wait for the opponent to begin and then
Block-Attack
Block-Attack
and so on.
I recommend you not to use your Special. It will probably end in a perfect block. So just keep your stars until your opponent uses his special, to counter it. This way youll be on the safe side and will get some damage + if you got lucky.