German law has had and still has difficulty openly accepting punitive damages as part of its legal system and explaining how noncompensatory damages can fit into a system presumably restricting the law id damages to compensation. As far as damages for pain and suffering are concerned, court and legal writers still try to explain the aforementioned deviations from a plain compensatory system by inventing the idea of " satisfaction." But this explanation is no longer persuasive in cases in which courts rely on deterrence as the German Federal Court of justice did in the Caroline of Monaco cases. Deterrence being among the predominant purposes of punitive damages, the noncompensatory approach of German courts must be classified as punitive.