Karen Goldberg’s husband was killed in a terrorist bombing in Israel. She filed a suit in a U.S. federal court against UBS AG, a Switzerland-based company. She claimed that UBS had aided in her husband’s killing because it had provided services to the terrorists. UBS argued that the case should be transferred to another country. The United States has a common law system. Other nations have civil law systems. What are the key differences between these systems? [Goldberg v. UBS AG, 690 F.Supp.2d 92 (2010)]