Punitive. The Second Circuit has affirmed an award of $1 billion in punitive damages.

The damage award was based on the district court's finding that the appellants "engaged in a coordingated campaign of lies and misrepresentation in order to swindle Motorola of more than $2 billion" and that, "threatened with exposure, [appellants] resorted not only to further lies and corporate manipulations, but even to obstruction of justice and, ultimately, misrepresentations to this court."

I think it was the misrepresentation to the court that really did it.

The decision in Motorola Credit Corp. v. Uzan can be found here.