Many other courts have required a PRP-plaintiff to show a § 107(b) defense in order to maintain a cost recovery action but have done so without specifically rejecting Rumpke. See, e.g., New Castle, 111 F.3d at 1124 (acknowledging, without adopting, that a party entitled to a defense under § 107(b) may bring a § 107(a) action against other PRPs); Advanced Technology Corp. v. Eliskim, Inc., 87 F.Supp.2d 780, 784 (N.D.Ohio 2000); M & M Realty Co. v. Eberton Terminal Corp., 977 F.Supp. 683, 686 (M.D.Pa.1997) (“We conclude that, under the circumstances alleged in this case, if M & M can establish that it is an innocent landowner under Section 107(b)(3), it will be entitled to bring a cost recovery action.”); Sinclair Oil Corp. v. Dymon, Inc., 988 F.Supp. 1394, 1396 n. 1 (D.Kan.1997) (<HOLDING>). In urging the court to recognize an exception
recognizing a criminal defendants right to present a complete defense holding that the avoidance powers provide for recovery only if the recovery is for the benefit of the estate holding that there is no right of recovery against individual defendants under the ada recognizing unconscionability as a generally available contract defense recognizing a prpplaintiffs right to cost recovery if a  107b3 defense is available