It’s probably not possible. I wouldn’t map the (EU) GDPR on how a US-like legal system works. E.g. it’s very unlikely that the regulator seeks maximum penalties

It’s probably not possible. I wouldn’t map the (EU) GDPR on how a US-like legal system works. E.g. it’s very unlikely that the regulator seeks maximum penalties in the EU, and worst case you could go to court arguing that a penalty is non proportional compared to other cases (and win) The maximum fine is a cap, not a guideline.