In civil law systems, such as Mexico, a distinction is made between civil law (‘derecho civil’) and commercial law (‘derecho mercantil’), which can be confusing to persons unfamiliar with the system. As is the case in common law jurisdictions, law in civil law systems can be divided into public law and private law, the latter being those laws that govern relationships between and among private parties, regarding which the state functions more as a ‘supervisor’ or an ‘umpire’ than as an authority. Public law would include constitutional law, administrative law, etc. In turn, private law comprises civil law, ie those rules governing the status, rights, and obligations of the residents of the state as persons, their property, their estates, their obligations, and their contracts; and commercial law, those rules governing all acts of the residents of the state that have a profit motive, which in Mexico—as well as in other jurisdictions—are called ‘acts of commerce’ (‘actos de comercio’).