Courts have grappled with the scope of CERCLA arranger liability ever since the U.S. Supreme Court’s 2009 decision in Burlington Northern & Santa Fe Railway Co. v. United States. Two opposite decisions on nearly identical facts illustrate the variety of approaches. In the first, a manufacturer’s actions related to the sale of PCB-laden scrap paper did not show the requisite intent to dispose; in the second, evidence gleaned from documents and expert testimony was the primary basis for holding the same manufacturer liable as an arranger. The latter outcome suggests the importance of circumstantial evidence in these cases, and counsel should seek discovery of such evidence at an early stage.