That's a difficult question for me to answer. There are a lot of complex issues that we are dealing with and it's not always clear. The frameworks are taken as a whole, and it's kind of tough to take little bits of them and compare.
I can point out a couple of differences. Probably the biggest difference, without saying whether it's good or bad—my colleagues may comment—is that in the U.S., software patenting is prevalent. In Canada, it is not.
This is an issue where Canadian software companies are brought up in a school of thought where software is not patentable and they can face challenges when they enter the U.S. market, which is thoroughly patented. That was the example Sylvain gave of patent thickets in the United States.