Shandong High People’s Court Releases Typical Cases of Punitive Damages for Intellectual Property Rights
Published 27 March 2026
Sarah Xuan
On March 16, 2026, the High People’s Court of Shandong Province released typical cases of punitive damages for intellectual property rights (IPR) at the Provincial Court IPR Adjudication Work Symposium. These typical cases cover various types, including invention patent infringement, trademark infringement, unfair competition, coordination between criminal and civil procedures, livestreaming sales, and evidence collection via short videos. They centrally reflect that judicial protection of IPR has moved beyond merely “stopping infringement” toward a stage of strict protection characterized by “increasing the cost of infringement and reshaping market expectations”.
The following is an introduction to and summary of this batch of typical cases.
1. Invention Patent Infringement Case Concerning “Long-Chain Dicarboxylic Acid” This case is the one that best reflects the intensity of protection for technological innovation in this batch of cases. According to the case materials, the plaintiff is the patentee of the invention titled “Refining Process for Producing Long-Chain Dicarboxylic Acid via Biological Fermentation”. The defendant had previously been found to have committed patent infringement for using a refining process identical to the patent at issue and manufacturing and selling products by leasing relevant production lines. After the effective judgment of the prior case was rendered, the defendant continued to lease the same infringing production line to carry out manufacturing and sales activities. Accordingly, the court determined that the acts in the subsequent litigation still constituted patent infringement. Regarding the compensation liability, the court further determined that the defendant’s subjective malice was obvious and the circumstances were objectively serious, based on facts such as obtaining secrets through a former employee of the plaintiff, associated contact with the patented method, obtaining and disclosing trade secrets, and continuing the infringement after the prior judgment became effective. In terms of damage calculation, the court combined the sales volume of the infringing products, the sales price, the plaintiff’s average operating profit margin, and the technical contribution rate of the refining process at issue to the overall production process. The court calculated the plaintiff’s actual loss to be approximately RMB 13,469,900, which was used as the base for punitive damages. A two-fold multiplier for punitive damages was determined, totaling a potential compensation amount of RMB 40,409,700. However, as the plaintiff’s claim was for RMB 30,000,000, the court ultimately granted the full request of RMB 30,000,000.
The adjudicatory value of this case lies not only in the high amount of compensation but also in the court’s normative evaluation of “repeated infringement” and “continued infringement after a prior judgment”. Carrying out the same type of infringing acts after they have been judicially confirmed as infringement is in itself one of the strongest proofs of intentionality and seriousness. This case also reflects another important adjudicatory method: in patent method infringement, the court did not mechanically use the profit of the entire product as the basis for compensation. Instead, through the introduction of a technical contribution rate, the value of the patented method within the overall process was proportionalized. This approach prevents the compensation amount from being divorced from the actual contribution of the patented technology and ensures that high compensation is built upon a more verifiable and persuasive calculation logic. For technology-intensive industries, this adjudicatory path of “precisely determining the base + strictly applying punitive damages” helps enhance the predictability of judicial protection for innovators.
2. Trademark Infringement Case Concerning “Dabeinong” Feed This case demonstrates new developments in the application of punitive damages in agricultural brand protection and the use of network evidence. In this case, an ordinary licensee authorized by the trademark registrant filed the lawsuit. The defendant company prominently used signs such as “Dabeinong” on the feed products it produced and sold. The individual defendant not only issued production orders directly through a personal WeChat account and settled payments using a personal account but also promoted the shipping and receiving status of the products involved via TikTok (Douyin) short videos. The court determined that the company and the individual jointly implemented the production and sales activities, constituting joint trademark infringement. In determining compensation liability, the court specifically noted that the individual defendant had long been employed by an affiliate of the rights holder and had a clear awareness of the trademark at issue. The defendant continued the infringement after receiving a request to cease. The company’s primary business was infringing operations. Furthermore, the defendants refused to provide financial account books, concealing evidence of infringing profits. Based on the shipping and receiving conditions reflected in the short videos, the court calculated the sales volume of the infringing products to be 412 tons per month. Combined with an infringement period of 36 months, the product price, and a gross profit margin of 11.7%, the infringing profit was determined to be RMB 11,005,551.65. Using this as a base, a one-fold multiplier for punitive damages was applied. Although the calculated total exceeded the plaintiff’s claim, the court ultimately awarded RMB 20,000,000 as requested.
The particular focus of this case is the functional positioning of short video evidence by the court. In traditional IPR infringement cases, rights holders often face difficulties in proving sales volume, as account books are controlled by the infringing party who refuses to submit them. This case converted the short video content actively released by the infringer into an important source of evidence for determining sales volume, which is an active response to evidence rules in a digital environment. Short videos, livestream playbacks, and promotional content on social platforms are no longer merely materials showing infringing acts; they may directly serve as tools to prove the scale, duration, and even the profit level of the infringement. Furthermore, the court comprehensively incorporated factors such as “former employment with an affiliate of the rights holder”, “continuing infringement after notice”, “engaging in infringement as a primary business”, and “refusing to submit account books” into the evaluation system for intentionality and seriousness. This indicates that the application of punitive damages does not rely on a single factor but emphasizes a holistic judgment of subjective malice and objective harm. This adjudicatory logic has strong exemplary significance for agricultural sectors such as agricultural supplies, feed, and the seed industry, where the risk of brand confusion is high.
3. Trademark Infringement and Unfair Competition Case Concerning “Meinian” Physical Examination Services This case presents a composite compensation structure where trademark infringement and the unauthorized use of enterprise names coexist. In the case, the plaintiff is the holder of the “Meinian” series of trademarks. In the process of providing physical examination services, the defendant used signs such as “Meinian” and an enterprise name containing the word “Meinian”. The court determined that the defendant’s actions constituted both trademark infringement and unfair competition. Regarding the compensation allocation method, the court did not generally categorize all infringing income under a single legal relationship. Instead, based on actual usage, it distinguished the contributions of the accused signs and the accused enterprise name to the infringing profits, determining a contribution rate of 80% for trademark rights and 20% for enterprise name interests. For the trademark infringement part, the court identified intentional infringement and serious circumstances based on several facts: the defendant’s legal representative had served as the legal representative of an entity authorized by the rights holder; the primary business was physical examination services using the “Meinian” signs; there were acts of counterfeiting trademarks; and the infringement led to the suspension of the authorized entity’s business. Based on a base of RMB 6,546,844.59, a one-fold multiplier for punitive damages was applied. For the unfair competition part, compensation was calculated separately for the 20% profit attributed to enterprise name infringement. The court ultimately awarded RMB 14,730,400.33 in damages and RMB 100,000 in reasonable expenses.
The institutional significance of this case lies in the court’s refusal to abandon the distinction between different bases for claims, even though the infringing acts were highly intertwined in commercial appearance. Through “contribution rate splitting”, the court established a clear boundary of liability between trademark law and the Law Against Unfair Competition. This method helps prevent two scenarios: first, it avoids over-evaluation by attributing all infringing profits simply to trademark infringement; second, it avoids underestimating the independent damage caused by the unauthorized use of enterprise names due to the concurrence of rights. For service industry brands such as physical examinations, education, medical aesthetics, and franchising, where enterprise names, store signs, service marks, and promotional language often overlap, this case provides a refined and replicable adjudicatory paradigm. Particularly noteworthy is the court’s presumption of intentionality through the relationship between historical business identity, exclusive regional authorization arrangements, and the start time of the accused party’s operations, which aligns the determination of subjective malice more closely with commercial reality.
4. Trademark Infringement Case Concerning “Huaxida” Nutritional Products This case highlights the strengthening function of punitive damages in the context of the coordination between criminal and civil procedures. In this case, the defendant had been convicted by a criminal judgment of the crime of counterfeiting registered trademarks for producing and selling nutritional products with the counterfeit “Huaxida HUAXIDA” trademark, and was sentenced to three years and six months of imprisonment and a fine of RMB 300,000. In the subsequent civil infringement litigation, the court determined the defendant’s actions constituted trademark infringement based on the criminal facts. It further pointed out that since the act of counterfeiting trademarks had reached the level of a criminal offense, it was sufficient to demonstrate obvious subjective intent to infringe and objectively serious infringement circumstances. In calculating the base, the court estimated the infringing profit to be RMB 3,428,412, based on a sales amount of RMB 6,856,824 and a sales profit margin of 50%. After comprehensively considering the subjective fault, infringement circumstances, and criminal penalties, the court determined a one-fold multiplier for punitive damages. The court ultimately awarded RMB 6,856,824 and reasonable expenses of RMB 40,755.86.
The significance of this case lies first in clarifying the evidentiary value of criminal adjudicatory facts for the application of civil punitive damages. For malicious infringing acts such as counterfeiting registered trademarks, a criminal conviction usually means that the degree of intent, scale of infringement, and social harm have reached a high level. Supporting civil punitive damages on this basis does not cause double evaluation; rather, it forms a synergy of “criminal sanctions + civil punishment”, addressing the violation of public order and the remedy for private rights respectively. Secondly, the court did not deny punitive damages simply because a criminal penalty had already been imposed. Instead, it treated the criminal penalty as a factor in the discretion of the multiplier, reflecting a comprehensive balance under the principle of proportionality. In other words, criminal liability does not automatically exclude civil punitive damages but will have a regulatory effect on the intensity of compensation. This approach is steady and aligns with the overall development direction of the intellectual property infringement liability system.
5. Trademark Infringement Case Concerning FILA Clothing This case centrally reflects a new expansion of the determination of intentional infringement in the context of livestreaming sales. In this case, a clothing company and its legal representative prominently used the “F” series trademarks when producing and selling clothing products and sold the infringing products through livestreams and by hiring multiple anchors to open livestream rooms. A typical feature was that while selling infringing products in the livestream room, genuine shopping bags, shoe boxes, and suitcases printed with the rights holder’s trademarks were displayed on-site. The court held that the defendant committed trademark infringement and determined that selling infringing products was its primary business. The infringing sales amount reached RMB 14,301,102.93, and the infringing profit was estimated to be RMB 4,290,330.88 based on a 30% gross profit margin for clothing retail. Combining factors such as the display of genuine products in the livestream room, the business model, and the scale of infringement, the court determined the defendant’s actions constituted intentional infringement with serious circumstances and applied a one-fold multiplier for punitive damages. As the calculated total was higher than the plaintiff’s claim, the court ultimately awarded RMB 6,000,000 and reasonable expenses of RMB 35,000 as requested.
The most significant aspect of this case is that the court evaluated “displaying genuine products while selling infringing products via livestream” as an important circumstance of intentional infringement. This determination breaks through the traditional path of judging “knowledge” in trademark counterfeiting cases, which relied primarily on factors like source of goods, industry experience, and notice warnings. Instead, it captured the marketing psychology mechanism in livestreaming scenarios: displaying genuine products is not a neutral display but an intentional attempt to use the appearance, brand association, and consumer trust of genuine products to create an illusion of “same source”, “same store”, or “same quality” for the infringing goods, thereby increasing the conversion rate. Such behavior is more misleading than general trademark parasitism and better reflects the subjective malice of the perpetrator. Therefore, this case enriches the identified circumstances of intentional infringement in the livestreaming e-commerce environment and has strong practical relevance for platform governance, anchor compliance, and brand protection.
Comment From these five cases, it can be seen that the typical cases released by the Shandong High People’s Court convey at least four clear signals at the institutional level:
First, punitive damages are no longer a symbolic system “cautiously applied in principle”. Instead, they have become a normalized tool consistently applied in scenarios involving repeated infringement, counterfeiting and parasitism, engaging in infringement as a primary business, refusal to submit account books, and utilizing new network marketing methods to expand the scale of infringement.
Second, the court’s determination of the compensation base increasingly emphasizes refined proof. Whether it is the technical contribution rate of a patented method, the sales volume reflected in short videos, the estimated profit substitution for service brands, or the introduction of gross profit margins for the clothing retail industry, all reflect an adjudicatory orientation of being “strict but not imprecise”.
Third, the court’s grasp of subjective malice has clearly expanded from “knowledge of the existence of rights” to factors closer to the reality of market transactions, such as “business identity relationships”, “continued infringement after a prior case”, “infringing business models”, and “scenario-based marketing designs”.
Fourth, punitive damages, unfair competition liability, and criminal liability are not mutually exclusive. Instead, they can form a complementary link under different institutional objectives.
From the perspective of further theoretical and practical development, this batch of cases also raises questions worth further discussion. For example, in different cases, the selection of parameters such as profit margins, contribution rates, and substitute profits still requires a stronger evidentiary basis and verifiability to reduce the uncertainty of parties’ expectations regarding calculation methods. Similarly, regarding the determination of “engaging in infringement as a primary business”, it remains necessary in the future to clarify application thresholds through more unified adjudicatory standards to avoid affecting the stability of rules due to different factual expressions in individual cases. Overall, what these cases demonstrate is not a simple pursuit of high compensation amounts, but an effort to combine deterrence with precision in fact-finding, liability allocation, and compensation calculation. As the rules for applying the punitive damages system continue to mature, such cases will not only continue to serve as adjudicatory guides but will also further promote the deep unification of protecting innovation results and maintaining a fair competition order.
The following is an introduction to and summary of this batch of typical cases.
1. Invention Patent Infringement Case Concerning “Long-Chain Dicarboxylic Acid” This case is the one that best reflects the intensity of protection for technological innovation in this batch of cases. According to the case materials, the plaintiff is the patentee of the invention titled “Refining Process for Producing Long-Chain Dicarboxylic Acid via Biological Fermentation”. The defendant had previously been found to have committed patent infringement for using a refining process identical to the patent at issue and manufacturing and selling products by leasing relevant production lines. After the effective judgment of the prior case was rendered, the defendant continued to lease the same infringing production line to carry out manufacturing and sales activities. Accordingly, the court determined that the acts in the subsequent litigation still constituted patent infringement. Regarding the compensation liability, the court further determined that the defendant’s subjective malice was obvious and the circumstances were objectively serious, based on facts such as obtaining secrets through a former employee of the plaintiff, associated contact with the patented method, obtaining and disclosing trade secrets, and continuing the infringement after the prior judgment became effective. In terms of damage calculation, the court combined the sales volume of the infringing products, the sales price, the plaintiff’s average operating profit margin, and the technical contribution rate of the refining process at issue to the overall production process. The court calculated the plaintiff’s actual loss to be approximately RMB 13,469,900, which was used as the base for punitive damages. A two-fold multiplier for punitive damages was determined, totaling a potential compensation amount of RMB 40,409,700. However, as the plaintiff’s claim was for RMB 30,000,000, the court ultimately granted the full request of RMB 30,000,000.
The adjudicatory value of this case lies not only in the high amount of compensation but also in the court’s normative evaluation of “repeated infringement” and “continued infringement after a prior judgment”. Carrying out the same type of infringing acts after they have been judicially confirmed as infringement is in itself one of the strongest proofs of intentionality and seriousness. This case also reflects another important adjudicatory method: in patent method infringement, the court did not mechanically use the profit of the entire product as the basis for compensation. Instead, through the introduction of a technical contribution rate, the value of the patented method within the overall process was proportionalized. This approach prevents the compensation amount from being divorced from the actual contribution of the patented technology and ensures that high compensation is built upon a more verifiable and persuasive calculation logic. For technology-intensive industries, this adjudicatory path of “precisely determining the base + strictly applying punitive damages” helps enhance the predictability of judicial protection for innovators.
2. Trademark Infringement Case Concerning “Dabeinong” Feed This case demonstrates new developments in the application of punitive damages in agricultural brand protection and the use of network evidence. In this case, an ordinary licensee authorized by the trademark registrant filed the lawsuit. The defendant company prominently used signs such as “Dabeinong” on the feed products it produced and sold. The individual defendant not only issued production orders directly through a personal WeChat account and settled payments using a personal account but also promoted the shipping and receiving status of the products involved via TikTok (Douyin) short videos. The court determined that the company and the individual jointly implemented the production and sales activities, constituting joint trademark infringement. In determining compensation liability, the court specifically noted that the individual defendant had long been employed by an affiliate of the rights holder and had a clear awareness of the trademark at issue. The defendant continued the infringement after receiving a request to cease. The company’s primary business was infringing operations. Furthermore, the defendants refused to provide financial account books, concealing evidence of infringing profits. Based on the shipping and receiving conditions reflected in the short videos, the court calculated the sales volume of the infringing products to be 412 tons per month. Combined with an infringement period of 36 months, the product price, and a gross profit margin of 11.7%, the infringing profit was determined to be RMB 11,005,551.65. Using this as a base, a one-fold multiplier for punitive damages was applied. Although the calculated total exceeded the plaintiff’s claim, the court ultimately awarded RMB 20,000,000 as requested.
The particular focus of this case is the functional positioning of short video evidence by the court. In traditional IPR infringement cases, rights holders often face difficulties in proving sales volume, as account books are controlled by the infringing party who refuses to submit them. This case converted the short video content actively released by the infringer into an important source of evidence for determining sales volume, which is an active response to evidence rules in a digital environment. Short videos, livestream playbacks, and promotional content on social platforms are no longer merely materials showing infringing acts; they may directly serve as tools to prove the scale, duration, and even the profit level of the infringement. Furthermore, the court comprehensively incorporated factors such as “former employment with an affiliate of the rights holder”, “continuing infringement after notice”, “engaging in infringement as a primary business”, and “refusing to submit account books” into the evaluation system for intentionality and seriousness. This indicates that the application of punitive damages does not rely on a single factor but emphasizes a holistic judgment of subjective malice and objective harm. This adjudicatory logic has strong exemplary significance for agricultural sectors such as agricultural supplies, feed, and the seed industry, where the risk of brand confusion is high.
3. Trademark Infringement and Unfair Competition Case Concerning “Meinian” Physical Examination Services This case presents a composite compensation structure where trademark infringement and the unauthorized use of enterprise names coexist. In the case, the plaintiff is the holder of the “Meinian” series of trademarks. In the process of providing physical examination services, the defendant used signs such as “Meinian” and an enterprise name containing the word “Meinian”. The court determined that the defendant’s actions constituted both trademark infringement and unfair competition. Regarding the compensation allocation method, the court did not generally categorize all infringing income under a single legal relationship. Instead, based on actual usage, it distinguished the contributions of the accused signs and the accused enterprise name to the infringing profits, determining a contribution rate of 80% for trademark rights and 20% for enterprise name interests. For the trademark infringement part, the court identified intentional infringement and serious circumstances based on several facts: the defendant’s legal representative had served as the legal representative of an entity authorized by the rights holder; the primary business was physical examination services using the “Meinian” signs; there were acts of counterfeiting trademarks; and the infringement led to the suspension of the authorized entity’s business. Based on a base of RMB 6,546,844.59, a one-fold multiplier for punitive damages was applied. For the unfair competition part, compensation was calculated separately for the 20% profit attributed to enterprise name infringement. The court ultimately awarded RMB 14,730,400.33 in damages and RMB 100,000 in reasonable expenses.
The institutional significance of this case lies in the court’s refusal to abandon the distinction between different bases for claims, even though the infringing acts were highly intertwined in commercial appearance. Through “contribution rate splitting”, the court established a clear boundary of liability between trademark law and the Law Against Unfair Competition. This method helps prevent two scenarios: first, it avoids over-evaluation by attributing all infringing profits simply to trademark infringement; second, it avoids underestimating the independent damage caused by the unauthorized use of enterprise names due to the concurrence of rights. For service industry brands such as physical examinations, education, medical aesthetics, and franchising, where enterprise names, store signs, service marks, and promotional language often overlap, this case provides a refined and replicable adjudicatory paradigm. Particularly noteworthy is the court’s presumption of intentionality through the relationship between historical business identity, exclusive regional authorization arrangements, and the start time of the accused party’s operations, which aligns the determination of subjective malice more closely with commercial reality.
4. Trademark Infringement Case Concerning “Huaxida” Nutritional Products This case highlights the strengthening function of punitive damages in the context of the coordination between criminal and civil procedures. In this case, the defendant had been convicted by a criminal judgment of the crime of counterfeiting registered trademarks for producing and selling nutritional products with the counterfeit “Huaxida HUAXIDA” trademark, and was sentenced to three years and six months of imprisonment and a fine of RMB 300,000. In the subsequent civil infringement litigation, the court determined the defendant’s actions constituted trademark infringement based on the criminal facts. It further pointed out that since the act of counterfeiting trademarks had reached the level of a criminal offense, it was sufficient to demonstrate obvious subjective intent to infringe and objectively serious infringement circumstances. In calculating the base, the court estimated the infringing profit to be RMB 3,428,412, based on a sales amount of RMB 6,856,824 and a sales profit margin of 50%. After comprehensively considering the subjective fault, infringement circumstances, and criminal penalties, the court determined a one-fold multiplier for punitive damages. The court ultimately awarded RMB 6,856,824 and reasonable expenses of RMB 40,755.86.
The significance of this case lies first in clarifying the evidentiary value of criminal adjudicatory facts for the application of civil punitive damages. For malicious infringing acts such as counterfeiting registered trademarks, a criminal conviction usually means that the degree of intent, scale of infringement, and social harm have reached a high level. Supporting civil punitive damages on this basis does not cause double evaluation; rather, it forms a synergy of “criminal sanctions + civil punishment”, addressing the violation of public order and the remedy for private rights respectively. Secondly, the court did not deny punitive damages simply because a criminal penalty had already been imposed. Instead, it treated the criminal penalty as a factor in the discretion of the multiplier, reflecting a comprehensive balance under the principle of proportionality. In other words, criminal liability does not automatically exclude civil punitive damages but will have a regulatory effect on the intensity of compensation. This approach is steady and aligns with the overall development direction of the intellectual property infringement liability system.
5. Trademark Infringement Case Concerning FILA Clothing This case centrally reflects a new expansion of the determination of intentional infringement in the context of livestreaming sales. In this case, a clothing company and its legal representative prominently used the “F” series trademarks when producing and selling clothing products and sold the infringing products through livestreams and by hiring multiple anchors to open livestream rooms. A typical feature was that while selling infringing products in the livestream room, genuine shopping bags, shoe boxes, and suitcases printed with the rights holder’s trademarks were displayed on-site. The court held that the defendant committed trademark infringement and determined that selling infringing products was its primary business. The infringing sales amount reached RMB 14,301,102.93, and the infringing profit was estimated to be RMB 4,290,330.88 based on a 30% gross profit margin for clothing retail. Combining factors such as the display of genuine products in the livestream room, the business model, and the scale of infringement, the court determined the defendant’s actions constituted intentional infringement with serious circumstances and applied a one-fold multiplier for punitive damages. As the calculated total was higher than the plaintiff’s claim, the court ultimately awarded RMB 6,000,000 and reasonable expenses of RMB 35,000 as requested.
The most significant aspect of this case is that the court evaluated “displaying genuine products while selling infringing products via livestream” as an important circumstance of intentional infringement. This determination breaks through the traditional path of judging “knowledge” in trademark counterfeiting cases, which relied primarily on factors like source of goods, industry experience, and notice warnings. Instead, it captured the marketing psychology mechanism in livestreaming scenarios: displaying genuine products is not a neutral display but an intentional attempt to use the appearance, brand association, and consumer trust of genuine products to create an illusion of “same source”, “same store”, or “same quality” for the infringing goods, thereby increasing the conversion rate. Such behavior is more misleading than general trademark parasitism and better reflects the subjective malice of the perpetrator. Therefore, this case enriches the identified circumstances of intentional infringement in the livestreaming e-commerce environment and has strong practical relevance for platform governance, anchor compliance, and brand protection.
Comment From these five cases, it can be seen that the typical cases released by the Shandong High People’s Court convey at least four clear signals at the institutional level:
First, punitive damages are no longer a symbolic system “cautiously applied in principle”. Instead, they have become a normalized tool consistently applied in scenarios involving repeated infringement, counterfeiting and parasitism, engaging in infringement as a primary business, refusal to submit account books, and utilizing new network marketing methods to expand the scale of infringement.
Second, the court’s determination of the compensation base increasingly emphasizes refined proof. Whether it is the technical contribution rate of a patented method, the sales volume reflected in short videos, the estimated profit substitution for service brands, or the introduction of gross profit margins for the clothing retail industry, all reflect an adjudicatory orientation of being “strict but not imprecise”.
Third, the court’s grasp of subjective malice has clearly expanded from “knowledge of the existence of rights” to factors closer to the reality of market transactions, such as “business identity relationships”, “continued infringement after a prior case”, “infringing business models”, and “scenario-based marketing designs”.
Fourth, punitive damages, unfair competition liability, and criminal liability are not mutually exclusive. Instead, they can form a complementary link under different institutional objectives.
From the perspective of further theoretical and practical development, this batch of cases also raises questions worth further discussion. For example, in different cases, the selection of parameters such as profit margins, contribution rates, and substitute profits still requires a stronger evidentiary basis and verifiability to reduce the uncertainty of parties’ expectations regarding calculation methods. Similarly, regarding the determination of “engaging in infringement as a primary business”, it remains necessary in the future to clarify application thresholds through more unified adjudicatory standards to avoid affecting the stability of rules due to different factual expressions in individual cases. Overall, what these cases demonstrate is not a simple pursuit of high compensation amounts, but an effort to combine deterrence with precision in fact-finding, liability allocation, and compensation calculation. As the rules for applying the punitive damages system continue to mature, such cases will not only continue to serve as adjudicatory guides but will also further promote the deep unification of protecting innovation results and maintaining a fair competition order.