Law360 Canada ( February 12, 2025, 8:25 AM EST) -- Appeal by Bao from trial judge's rejection of his plea for disgorgement of all fees paid to Welltrend Beijing (Welltrend) and from refusal to award him punitive damages. Bao provided legal services to Chinese citizens seeking to immigrate to Canada. Welltrend, an immigration consulting firm, entered into a contract with Bao to represent its clients applying for Canadian visas. The contract provided that Welltrend should not forge Bao’s signature. The contract pertained to applications to the Government of Canada only and did not cover applications to provincial nominee programs. Under the contract, Bao provided immigration services only for applicants to the federal immigration program. Later, Bao discovered that Welltrend forged his signature on 25 applications to Nova Scotia. Bao sued Welltrend for breach of contract, conspiracy to injure, fraud and unjust enrichment. He sought disgorgement of all fees received by Welltrend using his forged signature. The judge concluded that the claims in conspiracy to injure, fraud, and unjust enrichment could not succeed on the record before him. He awarded Bao $400,000 in damages against Welltrend for its wrongful conduct. Bao submitted that the judge erred in failing to impose liability on the individual respondents based on conspiracy and fraud and in refusing to award punitive damages....