In this issue the cases are: Fourth Circuit, in upholding criminal convictions, holds that discharges of pollutants to public sewers that flow to waters of the U.S. are subject to CWA: U.S. v. Hartsell; Third Circuit affirms district court's use of wrongful profits approach to calculating economic benefit factor of CWA penalty and finds no error in considering parent companies finances to determine impact of penalty on violator: U.S. v. Municipal Authority of Union Township, and Tenth Circuit holds that injunctive relief is not a penalty for purposes of 28 U.S.C. (inset) 2462 and that the concurrent remedy rule does not bar the government's claim for equitable relief: U.S. v. Telluride Co.