In Adams v. Murakami (1991) 54 Cal. 3d 105 [284 Cal. Rptr. 318, 813 P.2d 1348] California Supreme Court held that "A reviewing court cannot make a fully informed determination of whether an award of punitive damages is excessive unless the record contains evidence of the defendant's financial condition." ( Id. at p. 110.) A punitive damages award is excessive if it is disproportionate to the defendant's ability to pay. ( Id. at p. 112.) "The most important question is whether the amount of the punitive damages award will have deterrent effect--without being excessive. Even if an award is entirely reasonable in light of [the nature of the misconduct and the amount of compensatory damages], the award can be so disproportionate to the defendant's ability to pay that the award is excessive for that reason alone." ( Id. at p. 111, italics omitted.) Thus, an award of punitive damages may be excessive when, for example, such award exceeded one-third of the defendant's net worth. (Adams, supra, at p. 112.) The purpose for requiring some evidence of a defendant's financial condition is to allow a reviewing court to reach a reasonably informed decision, rather than having to speculate as to whether the award is appropriate or excessive. (Ibid.) What evidence of a defendant's financial condition is sufficient to allow proper review of an award of such damages? After Murakami, various courts have concluded that evidence of the defendant's annual income, standing alone, is not "meaningful evidence." (See, e.g., Lara v. Cadag (1993) 13 Cal. App. 4th 1061, 1064 [16 Cal. Rptr. 2d 811].) However, at least one court has held that evidence of the profits wrongfully gained by the defendant is, in itself, adequate evidence upon which to base an award of punitive damages. (Cummings Medical Corp. v. Occupational Medical Corp. (1992) 10 Cal. App. 4th 1291, 1298-1301 [13 Cal. Rptr. 2d 585] (Cummings); but see Robert L. Cloud & Associates., Inc. v. Miksell (1999) 69 Cal. App. 4th 1141, 1152 [82 Cal. Rptr. 2d 143] and Kenly v. Ukegawa (1993) 16 Cal. App. 4th 49, 56-57 [19 Cal. Rptr. 2d 771] [disagreeing with Cummings because the evidence of the illegally obtained profits gives only the defendant's assets without its liabilities; what is required is evidence of the defendant's ability to pay the damage award].)