Inc. v. Aigner Corp., 30 F.3d 761, 764 (7th Cir.1994)). As an initial matter, although NECC cites United Techs, for the proposition that only “a PRP who spontaneously initiates a cleanup without governmental prodding” may be entitled to pursue an implied action for contribution, the First Circuit has never in fact held this explicitly. Id. at 99 n. 8. In United Techs., the First Circuit merely suggested that this might be the case, citing Key Tronic, but refused to take a position on the matter. Id. There is, therefore, no clear controlling precedent as to whether, if an implied right to contribution exists, a PRP in Emhart’s position may take advantage of it. Authority in other circuits, although not directly on point, is conflicting. Compare Atl. Research, 459 F.3d at 834-836 (<HOLDING>), with Metro. Water, 473 F.3d at 836 (declining
holding that such an implied right exists at minimum for innocent parties holding that such a duty exists holding that a private right of action exists holding an implied right of action under section 36a holding that no private right of action exists