The amount in controversy under CAFA is the defendant’s possible liability, not likely or probable liability. When the complaint prays for an unspecified amount of punitive damages, a removing defendant can meet its burden of showing its possible liability for an amount of punitive damages by presenting evidence of the compensatory to punitive damage ratio(s) awarded in other cases alleging claims under the same or a similar statute. The defendant need not show that the other cases involved similar facts. The defendant can use the same approach to show how much in attorney fees it may potentially be liable for. It can present evidence of the attorney fees awarded to a successful plaintiff on a claim under the same or a similar statute. Finally, the plaintiff cannot rely on the defendant’s statute of limitations defense to diminish the amount in controversy since evaluating the defense and its probable effect on the ultimate damage award would require an impermissible ruling on the merits where removal turns only on jurisdiction, not merits.