548, 973 P.2d 527 (1999). The court reasoned that “to interpret the words ‘each violation’ to authorize a $2,500 sanction for each and every failure \.. would result in an unreasonable or oppressive statutory penalty,” while on the other hand, “to take all violations constituting evidence of a business practice in violation of a particular rule or regulation and count them as only one violation would be equally unreasonable.” Id. at 534-35, 206 Cal.Rptr. 164 (citing Hale, 22 Cal.3d at 399, 149 CaLRptr. 375, 584 P.2d 512). Therefore, the court concluded, a trial court should use a circumstances-based analysis to determine what penalties were justified based on the defendants’ conduct. Id.; see also Hewlett v. Squaw Valley Ski Corp., 54 Cal.App.4th 499, 536-37, 63 Cal.Rptr.2d 118 (1997) (<HOLDING>). We further note that when a penalty scheme
holding that each converterdecoder manufactured or distributed in violation of  553 is a separate violation of the statute holding that though we do not have exclusive jurisdiction over unfair competition claims our own circuit law nonetheless determines when inequitable conduct also constitutes unfair competition holding that a court cannot impose procedural re quirements on an agency beyond the minimum requirements imposed by statute holding that as in an action alleging infringement of a mark likelihood of confusion is the essence of an unfair competition claim holding that a trial court had discretion to construe an unfair competition statute which imposed a minimum of 2500 penalty for each violation as allowing it to impose damages based on separate instances of wrongful tree harvesting rather than the number of trees removed