In AIU Insurance Company v. Superior Court (1990) 51 Cal.3d 807, the Supreme Court faced the issue of whether insurers were obligated to provide coverage under their comprehensive general liability (CGL) policies to a corporation (FMC) for any environmental cleanup and response costs awarded in third-party suits against FMC by U.S. and local administrative agencies under environmental laws. (See AIU, supra, 51 Cal.3d at pp. 813-815.) In addressing this issue, the Court resolved three questions determinative to coverage. First, the Court held FMC would be "legally obligated" to pay cleanup costs by any adverse orders issued in the third-party suits because "legally obligated" includes equitable relief like injunctive relief and recovery of response costs. (Id. at p. 818.) Second, the Court held the response costs, including reimbursement of government response costs and the costs of compliance with injunctions, constitute "damages" under the CGL policies. (See id. at pp. 825-842.) Third, the Court held government claims for injunctive relief and environmental cleanup costs, with the exception of prophylactic costs, allege "property damage" under the CGL policies. (See id. at pp. 842-843.)