court held that it was not a stay violation for the United States to reduce to judgment (but not enforce) its claim for response costs under the Comprehensive Environmental Response, Compensation, and Liability Act, better known as "CERCLA.” Id. at 209. Here, a possible result of the ITC Action would not involve any monetary award against Spansion, but if Samsung's position is upheld, immediate injunctive relief directed against Spansion's ability to import its products would follow. Thus, the Samsung Action not only implicates the stay of § 362(a)(1), but also the stay of § 362(a)(3), which prevents any act to exercise control over property of the estate. 8 . See also Koken v. Reliance Group Holdings, Inc. (In re Reliance Group Holdings, Inc.), 273 B.R. 374, 386 (Bankr.E.D.Pa.2002) (<HOLDING>) 9 . The Qimonda Court also recognized that the
holding that an emergency petition by an insurance commissioner in her capacity as liquidator of an insurance company that was whollyowned by the debtor holding company was not an exercise of police and regulatory powers because it sought to take control of the debtors assets to allow certain policyholders and creditors to gain a pecuniary advantage over other creditors of the debtors estate holding secured creditors refusal to turn over property of debtors estate to debtor upon demand constituted an exercise of control over such property in violation of automatic stay holding that notice and a hearing were required before the commissioner of insurance could require an insurance company to change its definition of at fault in order to secure approval of an increase in insurance rates holding that the interest of the public  especially the debtor and creditors  could limit compensation to a debtors counsel holding that a closing protection letter offering to indemnify a mortgage company was not an insurance contract where although issued by an insurance company there was no distribution of the risk