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3446 REVIEW DENIED Civil penalties under the unfair competition law and false advertising law are not punitive damages and need not be supported by the same evidence that would be necessary to support an award of punitive damages; the award of restitution in addition to civil penalties does not constitute a double penalty in violation of due process.CitationPEOPLE v FREMONT LIFE (Deceptive Annuities) 104 CA4 508 [See: B&PC 17200 etseq, 17500 etseq; BMW v Gore 517 US 559; City and County v Sainez 77 CA4 1302; People v. Bestline 61 CA3 879; Fletcher v Security Pacific 23 C3 442]
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