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Section 9601(35)(C) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) may amend the traditional classes of liable parties, holding responsible intermediate land-owners who convey properties without disclosing their knowledge of contamination. To date, however, courts have failed to settle on whether § 9601(35)(C) constitutes a new and independent basis for liability. This Note provides a discussion of the current status of the law on intermediate landowner liability, presents four scenarios in which the lack of consistency in judicial interpretation of § 9601(35)(C) results in mischievous land transfers, and finally, suggests that courts should use the section as an independent basis for intermediate owner liability to achieve the policy goals of CERCLA.