Quantum of damages for copyright infringement: which jurisdiction?

The decision of the UK's Supreme Court today in Lucasfilm Ltd, Star Wars Production Ltd and Lucasfilm Entertainment Co Ltd v Ainsworth and Shepperton Design Studios Ltd (judgment here; IPKat note here; shorter note on the 1709 Blog here) has already received plenty of coverage.  We all now know that a Star Wars Stormtrooper helmet is not a "sculpture" for the purposes of UK copyright law and that Lucasfilm is entitled to bring proceedings in a British court in respect of claims of infringement of US copyright law.

Arising out of this is one small aspect, not so far covered elsewhere, which is troubling me.

Presumably, when any copyright owner is deciding whether to sue for infringement and seeks damages, the cost-effectiveness of making the claim will determine whether it is worthwhile to do so. Thus an expensive action to recover a small sum makes little or no sense while the expectation of sizable compensation makes the litigation a more appealing business proposition.

What I don't know, and therefore hope readers can advise me on, is this: where a British court applies the test of infringement of copyright under US law in respect of an act committed in the US, is it also bound to apply the US scale of damages -- which appears to be vastly more generous than the sort of damages awards made in the UK for infringement of UK copyright within the UK -- or does it assess liability by reference to US law and then calculate damages on its own local principles?  Can anyone point to a clear rule or judicial authority which establishes how quantum is calculated?

What happens to all that Jammie money?

The US $1.92 million copyright infringement award in favour of the Recording Industry Association of America (see 1709 Blog here) against single mother-of-four Jammie Thomas-Rasset works out at $80,000 per infringed track. This post does not seek to replicate the comments of others but just to ask this: what happens to the $1.92m in the event that it gets paid? How transparent are RIAA's accounts? Does it simply sit in the RIAA's coffers? Or does it get allocated to a litigation enforcement fund? How much, if any, is received by the individual recording companies whose works are infringed, and how much, if any, by the creatives?

Can anyone advise?

Rationale for copyright damages

Writing yesterday on Canada's approach to the award of damages in copyright infringement proceedings, Michael Geist states:

"Canada is one of the only countries in the world to have a statutory damages provision within its copyright legislation. It creates the prospect of massive liability - up to $20,000 per infringement - without any evidence of actual loss. This system may have been designed for commercial-scale infringement, but its primary use today is found in the U.S. where statutory damages led to the massive liability for one peer-to-peer file sharing defendant and leaves many defendants with little option but settlement. Before Canada faces similar developments, we should amend the statutory damages provision by clarifying that it only applies in cases of commercial gain".