done back to the individual cattle owners. Indeed, this is precisely what the “reasonable basis” standard is designed to avoid: The whole point of Restatement § 433A is that no specific evidence is required for apportionment so long as the evidence and method used are “reasonable.” Further, the Restatement embraces “simple” considerations rejected by the panel — -the number of cattle owned is a “simple,” yet sufficient, basis for apportionment. Even though it is impossible to determine the exact proportion of the contamination attributable to the Railroad parcel, the percentage of land ownership, like the number of cattle, provides one reasonable factor upon which to apportion liability under the Restatement. See United States v. Twp. of Brighton, 282 F.3d 915, 919-20 (6th Cir.2002) (<HOLDING>); United States v. Hercules, Inc., 247 F.3d
recognizing cercla successor liability holding  substantial continuity is untenable as a basis for successor liability under cercla holding that notice not required because cercla is a strict liability statute holding that apportionment of cercla liability is  a matter of federal common law holding that geographic divisibility may provide a basis for apportionment of cercla liability