The issue of whether investigatory expense is deemed “defense”; and, like other defense expense, recoverable as incurred wherever there is a potentiality of coverage, orisdeemed “indemnity”; and recoverable only at the end of coverage litigation, if coverage actually has been established, is one of the most significant issues in environmental coverage litigation today. It is particularly important because an insurance company's duty to defend is not tied to the coverage limits in the policy and may have vast, potentially unlimited, value.