Abstract
Counterfeiting is a global criminal challenge, particularly in the digital era marked by the rapid growth of e-commerce and online transactions. The criminal handling of this offense varies across countries, reflecting differences in legal systems and socio-economic contexts. This study examines the regulation and prosecution of counterfeiting crimes under the criminal laws of France and the United States, analyzing their key similarities and distinctions. Through comparative analysis, the paper identifies valuable insights and lessons that can serve as references for improving Vietnam’s criminal law framework to more effectively address counterfeiting in the digital age
