Yes, and there's also some info here specifically: https://www.ephere.com/plugins/autodesk/max/lucid/docs/1/Simulation_related_FAQ.html#Why-are-my-inflatable-rigid-cloth-objects-going-through-one-another
it turned out to be none of the suggested. i ran about a 100 tests last night. it looks like it has to do with particle size bellow 1.0cm. but i'm still going through all the cloth settings and how they relate to eachother. collision tests are next i guess