In Zazu Designs v. L'Oreal, S.A., 979 F.2d 499, 508 (7th Cir 1992), the Court of Appeals for the Seventh Circuit opined that corporate wealth is not an appropriate consideration for punitive damages awards because corporate defendants differ from individuals in three important respects. First, they are abstractions and are owned and controlled by individual investors. While a corporation itself may have great wealth, it is the individual investors who will bear the brunt of a punitive damages award and they may not be of great wealth. (Id. at 508.) Secondly, a corporation's net worth is a measure of its profits that have not been distributed to shareholders but instead have been reinvested in the corporation's ventures and operations. Basing a corporation's punitive damage award on its wealth will mean that corporations that have reinvested their profits will be more severely punished than corporations that distribute their profits. (Id.) Finally, in a products liability setting, larger corporations already have greater potential liability than smaller firms. Larger firms produce more of a given product than a smaller firm. Accordingly, when a large firm sells a defectively designed product, its potential liability for compensatory and punitive damages awards is already greater than that of a smaller firm. To increase an individual punitive damages award based upon the corporation's wealth is unnecessary, as wealthy corporations will already be paying punitive damages awards in more cases than smaller corporations. (Id. at 508-509.) These arguments, however, were dicta, raised only after the court had determined that defendant was not liable for the underlying claim and that its conduct was not sufficient to support a punitive damages award.