"The All China Environmental Federation (ACEF) won lawsuit against Zhenhua for its long-standing failure to curb the release of harmful gases…[which] made legal history by becoming China’s first public interest action to be brought against air polluters.…But …[t]he court rejected a request from ACEF for the imposition of punitive damages on Zhenhua Ltd…and the NGO was forced to cover [costly] legal expenses…. The outcome…highlighted the financial difficulty of prosecuting big, industrial firms, which has led to a rising number of NGOs opting not to pursue legal action…"