The United States and the State of South Dakota filed a Complaint in this case on April 14, 2016 alleging that the Defendants are jointly and severally liable for response costs related to the cleanup at the Site. 42 U.S.C. 9607(a) and 9613(g)(2). The Complaint requests recovery of costs that the United States and the State incurred responding to releases of hazardous substances at the Site near Lead, South Dakota. Both Defendants signed the Consent Decree and will pay a combined $10.3 million in cash, with CoCa Mines paying up to an additional $700,000 in future insurance recovery. The money will be used to help pay for response costs related to the cleanup at the Site. In return, the United States and the State of South Dakota agree not to sue the Defendants under Sections 106 and 107 of CERCLA, 42 U.S.C. 9606 and 9607. The Consent Decree would resolve the claims against the Defendants as described in the Complaint.