In recent years, policyholders have formulated a liability theory of coverage predicated upon the “all sums”; language commonly found in Comprehensive General Liability policy insuring agreements. The increasing reliance on this theory by policyholders has led to some particularly unusual results in the environmental litigation context. This article discusses the legal underpinnings of the “all sums”; position and examines its continued viability in the wake of growing opposition from courts across the country.