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In this article, Jenner & Block Partner Keri L. Holleb Hotaling and Associate Allison A. Torrence explore contribution issues under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) for companies that have entered into an administrative order on consent (AOC) with the U.S. Environmental Protection Agency (EPA). The article explains that while many parties choose to address CERCLA liability concerns through AOCs, courts are still struggling with the legal ramifications related to contribution claims following entry of an AOC. The authors caution that the U.S. Supreme Court’s seminal United States v. Atlantic Research Corp. and Cooper Industries, Inc. v. Aviall Services, Inc. decisions have created complex issues that parties should consider before entering into an AOC – most significantly, what type of CERCLA claim may be available and when the statute of limitations will begin to run on those claims. Incoming associate Alexander J. Bandza also contributed to the article.