definiens: means the natural or man - made environment ( including soil, land surface or subsurfacestrata, surface water, groundwater, sediment, ambient air ( including all layers of the atmosphere ), organic andinorganic matter, living organisms, and any other environmental - related medium or resource, natural or otherwise).b means any claim, action, cause of action, suit, proceeding, investigation, order, demand or notice ( written or oral ) by any person or entity alleging actual or potential liability ( including, withoutlimitation, actual or potential liability for investigatory costs, cleanup costs, governmental response costs, naturalresources damages, property damages, personal injuries, attorneys ’ fees or penalties ) arising out of, based on, resulting from or relating to ( a ) the presence, or Release or threatened Release into the Environment, of, or exposureto, any Hazardous Substances at any location, whether or not owned or operated by [COMPANY] or [COMPANY] or any of theirrespective Subsidiaries, as applicable, now or in the past, or ( b ) circumstances forming the basis of any violation, oralleged violation, of any Environmental Law