I would say the main distinguishing factor was the citizenship of Ms. Kazemi at the time the atrocities were committed. When Ms. Kazemi was unlawfully detained, tortured, beaten, and ultimately murdered in Iran, she held Canadian citizenship. She had been domiciled in the province of Quebec and was a citizen of Canada, and her estate was domiciled as a result in the province of Quebec.
So from the outset we faced fewer jurisdictional problems than Mr. Bouzari may have—although as Jayne mentioned, the courts never addressed the jurisdictional issue, having fallen, as Mark said, already on the state immunity issue. But Ms. Kazemi faced no issue there. The courts of Quebec clearly have jurisdiction to hear a suit, and I would say that's the principal distinguishing feature.
When Mr. Bouzari was tortured in Iran, he was not at the time a resident of Canada. He subsequently fled to Canada and pursued his justice here. I would say that's the main distinguishing factor.