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Clifford Chance

Clifford Chance


Talking Tech

Tech Policy Horizon Scanner

January 2023

Artificial Intelligence Data privacy Fintech Cyber Security 31 January 2023


Dry January. Layoffs. Fines. New year's resolutions. Welcome to 2023.

Tech is supposed to be nimble – move fast and break things, right? – but both companies and the sector have grown so large, that big changes happen a bit like an oil-tanker changes direction.

The signs of a change in direction can be seen as layoffs have continued this month across the board. TikTok is facing issues relating to US bans at both federal and state level relating to its Chinese ownership. Meta has received a fine which signals a challenge to its current ad-driven business model. All this shows that existing business models (purely ad-driven) are under pressure.

Where is the change? AI and the Metaverse have been an immediate focus of the start of the year as areas where there will be more investment, activity, and potentially, a slow, rolling revolution.

Microsoft made a big play with a multi-billion dollar investment in OpenAI. Microsoft's Chief Executive, Satya Nadella, said that AI could transform its business and that the partnership with OpenAI has been formed "around a shared ambition to responsibly advance cutting-edge AI research". It could change the face of search, and a range of other products.

Metaverse is the next, next big thing. has predicted that the global market for the metaverse will grow to US$231 billion by 2027, from an estimated almost US$53 billion in 2022. At the WEF in Davos, the Chief Executive of Qualcomm set out his vision of the future where internet connected glasses overtake smartphones as the personal computer of choice. He argued that the metaverse is the key difference as to why the technology would be successful this time.

On the new year's resolution front, metaverse initiatives are expected from the European Commission in May 2023. Stay with us throughout 2023 as we follow these trends


Chinese regulator approves collaborative medical data export research project with Dutch medical centre

On 18 January 2023, the Beijing office of the Cybersecurity Administration of China (Beijing CAC) announced that a collaborative research project between Beijing Friendship Hospital associated with Capital Medical University and the Academic Medical Centre of the University of Amsterdam has successfully passed a security assessment. The approval is the first time that the PRC regulator has given the green light to a security assessment of exported data. The approved research project is expected to provide practical guidance for further strengthening the safe management of medical and health data and promote international medical research cooperation. Beijing CAC also mentioned that it had received submissions from 16 institutions (involving industries across social media, healthcare, finance, automobile, civil aviation, etc.), out of which 10 institutions have passed through the examination of the completeness of the submission. Another project involving Air China has also been approved recently according to the announcement.

Chinese authorities issue Guiding Opinions on Promoting the Development of Data Security Industry

On 3 January 2023, 16 Chinese authorities, including the Ministry of Industry and Information Technology and the Cyberspace Administration of China, issued Guiding Opinions on Promoting the Development of the Data Security Industry (Data Security Guiding Opinions). The Data Security Guiding Opinions put emphasis on the protection of data security and the development and utilization of data resources. To further develop the data security industry, the Data Security Guiding Opinions outline seven fundamental tasks, including encouraging innovation, optimizing services, establishing standards, promoting the application of innovative products, supporting the development of the overall industry, attracting more talent and deepening international cooperation. The Data Security Guiding Opinions further propose certain implementing measures, including, among others, setting out preferential policies for those enterprises engaging in the development of data security and encouraging their cooperation with other types of companies.

Didi off the leash

In July 2021, the Cybersecurity Administration of China (CAC) announced a cybersecurity investigation into China's ride-hailing giant Didi and suspended new user registrations. Didi spent more than a year taking all-around corrective measures to address issues found during the investigation. On 16 January 2023, Didi made a statement through its social media account that Didi had obtained approval from the Office of Cybersecurity Review of the CAC to resume new user registrations. Didi also announced in the statement that it will take measures to ensure the security of its platform facilities and data and safeguard national cyberspace security going forward.

Hong Kong's tech companies and financial institutions to face increasing regulation

Hong Kong's Tech companies who use a range of technologies such as regulatory technology, AI and cloud computing to effectively run their business are facing increasing regulation. This also notably includes Financial Institutions whose businesses are becoming increasingly tech driven.

The Privacy Commissioner for Personal Data (PCPD) has suggested that it plans to work with the Hong Kong Government to undertake a review of the Personal Data (Privacy) Ordinance (PDPO) legislation with the aim to introduce new powers. These would include administrative penalties regimes and also the introduction of mandatory notifications for data breaches. This has been said to be in response to (i) repeated calls by the public and (ii) a rise in incidents of data breaches. Other changes, including in relation to risk management may also be expected.

Vietnam goes after green finance and green tech

Vietnam is implementing a roadmap to improve its legal framework to attract green finance and green technology. Deputy Prime Minister Tran Hong Ha called on corporations to increase investment, to support green growth in Vietnam, and to implement international climate change and sustainable development commitments, which notably include those delivered at the 26th United Nations Climate Change Conference of the Parties (COP26) in Glasgow. The response was positive – watch this space.

Digital public infrastructure in Singapore: collaboration opportunities with India explored

An official from Singapore's Central Bank has stated that Singapore would like to form a digital public infrastructure collaboration with India. The collaboration would be on the lines of India's 'Aadhaar' system (Hindi: 'base, foundation') , which is a national identity system. He also said there could be an opportunity to integrate India's Open Network for Digital Commerce (ONDC) with Singapore's 'Proxtera' to improve the finances and opportunities for small businesses in Singapore and India.

The idea is to reduce remittance costs through the Unified Payments Interface (UPI), PayNow and similar payments networks. Service providers would be able to facilitate the exchange of a sender's consent-based financial information. The hope is that this would create innovative credit solutions for remittance beneficiaries.

Hong Kong Government soon to issue institutional investors with tokenized green bonds

Hong Kong is unrelenting in its aim to establish itself as a crypto hub despite neighbors (such as Singapore) being discouraged to do so due to the current difficult market conditions currently facing the crypto industry. Hong Kong's Financial Secretary has stated at a recent conference that the Government has invited "several companies" to set up their international headquarters in Hong Kong and list there. The Financial Secretary also said that there are also "multiple pilot projects" which are being run with regulatory agencies. One of these is for the Government to issue tokenized green bond, and the aim of the projects overall is to test virtual assets' "technical advantages".


Data Services Act: European Commission consults on methodology and procedures to calculate supervisory fee

The European Commission has consulted on the methodology and procedures to calculate the supervisory fee under the Digital Services Act (DSA). The DSA entered into force on 16 November 2022 and includes new obligations for service providers designated as very large online platforms (VLOPs) or very large online search engines (VLOSE). To ensure the effective supervision and enforcement of the new rules, the Commission can levy a fee on providers under its supervision. The draft Delegated Regulation, which is the subject of the consultation, specifies the methodology and procedures to calculate and levy the supervisory fee. The consultation closed on 19 January 2023. The new rules will become applicable four months after organisations are formally designated as VLOPs or VLOSE, based on user numbers to be published by 17 February 2023. The Commission expects the obligations to kick in from the autumn of 2023.

Patents: package of new measures expected in April 2023

The European Commission will present a patent package on 26 April 2023. It will include legislative proposals on compulsory licencing of patents and standard essential patents (SEPs) as well as a revision of the legislation on supplementary protection certificates. The Commission's aim is to "work towards an efficient framework for standard essential patent licensing to best reflect the interests of their holders and implementers" as well as establishing "clear rules for the compulsory licensing of patents".

Metaverse: EU initiative expected in May 2023

The European Commission has included an "initiative on virtual worlds" in its work programme for the first six months of 2023. The Commission will not propose new legislation but rather "tools on developing open human-centric virtual worlds" which "provide a myriad of possibilities for industries and service sectors, the creative arts and citizens, as well as opportunities to address broader social challenges such as health and smart cities."

Open Data Directive: Commission defines high-value datasets to be made available for re-use

On 20 January 2023 the list of high-value datasets that public sector bodies will have to make available for re-use, free of charge, within 16 months under the Open Data Directive was published in the Official Journal. The Directive defines six thematic categories of high-value datasets: geospatial, earth observation and environment, meteorological, statistics, companies and mobility. Thierry Breton, European Commissioner for the Internal Market, said: "Data is a cornerstone of our EU industrial competitiveness. With the new list of high-value datasets, published today, we are unlocking a large amount of public data for the benefit of all. Start-ups and SMEs will be able to use this data to develop new products and innovative solutions that improve the lives of citizens in the EU and around the world."

Meta fined EUR 390 million by Irish data protection authority

The Irish data protection authority, the Data Protection Commission (DPC), fined Meta Ireland EUR 210 million for Facebook-related GDPR breaches and EUR 180 million for Instagram-related breaches, following two complaints submitted in May 2018. The decision comes after the European Data Protection Board issued a determination, following disagreements amongst EU data protection authorities, on the investigation in December 2022, which have been incorporated into the DPC's final decision. As well as the fines, which were revised upwards from an original base of EUR 28 million to reflect the EDPB's deliberations, Meta has also been directed to bring its data processing activities into compliance within three months.


Online Safety Bill: Remaining Stages concluded on 17 January

Penny Mordaunt, the UK Leader of the House of Commons, announced that the Remaining Stages of the Online Safety Bill concluded on Tuesday 17th January. The Online Safety Bill was introduced in the House of Commons on 17 March 2022. The Bill has five policy objectives:

  • to increase user safety online;
  • to preserve and enhance freedom of speech online;
  • to improve law enforcement’s ability to tackle illegal content online;
  • to improve users’ ability to keep themselves safe online; and
  • to improve society’s understanding of the harm landscape.

The Bill has been amended extensively while being read in the House and is under fierce debate with society and tech companies. MPs are pushing to make senior management of online companies personally criminally liable for pushing harmful content to children. The latest addition is a cross-party amendment signed by several senior MPs to designate content promoting LGBT+ conversion therapy as harmful. It is currently within the House of Lords. The second reading is scheduled to be on 1 February 2023.

Inaugural Meeting of the US-UK Comprehensive Dialogue on Technology and Data on 13 January

The U.S.-UK Comprehensive Dialogue on Technology and Data was originally launched by U.S. Secretary of Commerce Gina Raimondo and UK Secretary of State for the Department of Digital Culture, Media, and Sport (DCMS) Michelle Donelan in October 2022. The UK Government made a press release on 12 January 2023 that senior officials from the US and the UK Governments met and discussed three workstreams: 1) data; 2) critical and emerging technologies; and 3) secure and resilient digital infrastructure. Together they identified deliverables to address in 2023, including:

  • collaboration on facilitating global trusted data flows;
  • finalising and implementing a data bridge for US-UK data flows;
  • promoting open, interoperable, and secure telecommunication systems; and
  • identifying opportunities for cooperation between the UK and the U.S. semiconductor industry on skills, investments and R&D.

The officials agreed to review progress on a quarterly basis and meet again in the next formal Dialogue in January 2024. The dialogue covered very broad topics but is relevant to very hot topics such as Schrems and semiconductor industry development. We expect more related announcements in future.

Competition and Markets Authority (CMA) investigation into Apple: Apple seeks review of CMA decision

On 20 January 2023 Apple applied to the Competition Appeal Tribunal for a review into the CMA's 22 November 2022 decision to make a market investigation reference to investigate its supply of browser engines and browsers, and also its distribution of cloud gaming services through its app stores on mobiles in the UK. The ground of review advances that the CMA's reference was outside the powers of the CMA. Apple seeks that the decision is quashed and that the investigation launched is invalid with no legal effect. Apple also seeks interim relief.

UK Government consultation on draft Digital Government (Disclosure of Information) (Identity Verification Services) Regulations 2023

The UK Government is consulting on draft legislation that aims to improve how data is shared and used in the public sector. The Government seeks to make online identify verification easier and also more reliable, and to help ensure that a greater number of people can use digital public services. The Government say that this will allow their new identity verification system, GOV.UK One Login, to be used to full benefit and cites inclusion in its message. The legislation enables data sharing between specified public authorities. This the Government says is to enable more people to prove their identity, so anyone who seeks to use online services to be able to do so. Further legislation in relation to digital inclusion is planned according to the consultation, which will be designed to enable the use of "trusted digital identities in the UK" under Part 2 of the Data Protection and Digital Information Bill. The consultation closes on 1 March , 2023.



Resurrecting The Competition and Transparency in Digital Advertising Act

On January 11th, President Biden released a rare statement in an op-ed in the Wall Street Journal urging Democrats and Republicans to come together to pass strong bipartisan legislation to hold Big Tech accountable, urging lawmakers to strengthen anti-monopoly laws: "My administration has made strong progress in promoting competition throughout the economy, consistent with my July 2021 executive order. But there is more we can do. When tech platforms get big enough, many find ways to promote their own products while excluding or disadvantaging competitors—or charge competitors a fortune to sell on their platform. My vision for our economy is one in which everyone—small and midsized businesses, mom-and-pop shops, entrepreneurs—can compete on a level playing field with the biggest companies. To realize that vision, and to make sure American tech keeps leading the world in cutting-edge innovation, we need fairer rules of the road. The next generation of great American companies shouldn’t be smothered by the dominant incumbents before they have a chance to get off the ground."

President Biden's statement invoked support from both sides of the aisle. Senator Amy Klobuchar (D-MN) said "I'm glad the President continues to support efforts in Congress to pass federal privacy protections, hold social media companies accountable, and restore competition throughout the digital economy." Rep. Ken Buck (R-CO), the incoming chairman of the House Judiciary Subcommittee on Antitrust, Commercial, and Administrative Law, said during an event that one of his first priorities is resurrecting "The Competition and Transparency in Digital Advertising Act." This law would prohibit companies from owning more than one part of the digital ad ecosystem if they process more than $20 billion in digital ad transactions. For companies that make more than $5 billion in digital ad transactions, there are obligations that include a best interest duty, a best execution duty, transparency requirements, the use of firewalls between buy- and sell-side brokerages, and a fair access duty regarding data.

Lawmakers Press Forward on State and Federal Privacy Laws

In addition to strengthening laws to protection competition, President Biden's statement also urged lawmakers to pass laws to protect Americans' privacy, highlighting the need for clear disclosures, restrictions on data collection and targeted advertising, and protection for children. The statement suggests that President Biden's administration would continue to support efforts to pass comprehensive privacy legislation, despite failed efforts in 2022 to get a law on the books. 

In the meantime, as lawmakers take their seats following the 2022 elections, many states have already begun moving on state laws, pushing to join the ranks of California, Virginia, Colorado, Connecticut, and Utah. In the first few weeks of 2023, lawmakers have introduced (or reintroduced) state law proposals in New York, Indiana, Mississippi, Oregon, Kentucky, Tennessee, Hawaii, Iowa, and Massachusetts. Meanwhile, state legislators have also pushed forward various targeted consumer privacy laws, including laws protecting biometric data (Mississippi, New York, Maryland), health data (Washington), and children's data (West Virginia, Oregon). Not to be outdone, Utah, Colorado, Connecticut, and Virginia lawmakers have also introduced proposed amendments to their privacy laws, focusing on strengthening protections for children and genetic/health data.

US States are imposing TikTok bans due to cybersecurity concerns

Following on from its ban on all federal devices due to security concerns, Chinese-owned TikTok is additionally facing government restrictions in 27 US states. These bans include banning the use of or downloading of TikTok on state devices, as well as bans in relation to using government internet networks. The bans also impact the use of TikTok on public university internet networks. The states impacted include Florida, Virginia, and New Jersey.

TikTok is owned by ByteDance. US states are concerned that TikTok could be used by ByteDance to provide data to the Chinese Communist Party and US states want to protect their state information and mitigate the cybersecurity threat posed by China. Both Texas and Ohio have cited China's National Intelligence law from 2017. This law requires that companies registered assist China by gathering Intelligence, which includes sharing user data. TikTok has previously told US media that the US bans "are largely fueled by misinformation". Other Chinese apps such as WeChat have also been affected in some states.

Middle East

Collaboration between MoIAT and the Ras Al Khaimah Economic Zone promoting investment and industrial growth

On 19 January 2023, as part of the "Make it in the Emirates" campaign the Ministry of Industry and Advanced Technology (MoIAT) and Ras Al Khaimah Economic Zone (RAKEZ) signed a Memorandum of Understanding (MoU). The aim of the MoU is to improve collaboration to accelerate the adoption of advanced technologies by industrial companies and to enhance investment appeal in the UAE.

The deal was signed during Abu Dhabi Sustainability Week (ADSW) by Omar Suwaina Al Suwaidi, Under-Secretary of the Ministry of Industry and Advanced Technology, and Ramy Jallad, CEO of RAKEZ. Dr. Sultan bin Ahmed Al Jaber, Minister of Industry and Advanced Technology was also present for the signing.

Al Suwaidi said, "Our MoU with RAKEZ aligns with our commitment to boosting collaboration with government and private sector entities to drive the progress of our industrial sector. It serves the objectives of our national industrial strategy, Operation 300bn, to help create an attractive business environment for domestic and international investors looking to invest in the industrial sector. It also supports our objectives to enhance the growth and competitiveness of national industries, leverage innovation and advanced technologies in developing industrial solutions, and help transform the UAE into a global hub for future industries."

AI Centre of Excellence launched by Mohamed bin Zayed University of Artificial Intelligence (MBZUAI) and IBM

On 17 January 2023, as part of Abu Dhabi Sustainability Week’s World Future Energy Summit, a new AI Centre of Excellence was launched by MBZUAI in a collaboration with IBM. The aim of the Centre and the collaboration is to improve AI technology adoption and sustainability. The Centre is tasked with developing "carbon-neutral solutions to existing energy supplies, combat climate change, and further natural language processing (NLP) for Arabic dialects".

A key focus of the centre will be decarbonisation research where experts from both collaborators will focus on both mitigation and adaption for climate change. There will be joint teams to develop AI models with the aim of helping to inform clean and renewable energy deployment as part of the electrification of multiple sectors of the UAE economy. With a focus on Net Zero and the use of big data, the hope is to develop AI-based carbon-neutral technologies alongside enabling resilience and adaptation.

"United on Climate Action Toward COP28" and the circular economy: MoIAT makes plans

Ahead of January's Abu Dhabi Sustainability Week (ADSW) 2023 the Ministry of Industry and Advanced Technology (MoIAT) made an announcement to promote their theme "United on Climate Action Toward COP28" and the UAE's goal for a circular economy. The announcement detailed various initiatives and announced a new Memorandum of Understanding (MoU) to establish an investment partnership to build a circular economy. Initiatives included its green financing for industry to support the objectives of the "National Strategy for Industry and Advanced Technology (Operation 300 Billion)". Key programmes will also be highlighted to encourage industry to be sustainable, efficient, productive, and competitive by adopting Fourth Industrial Revolution (4IR) solutions.

Smart app launched for whistle-blowers by the Abu Dhabi Accountability Authority (ADAA)

This month it has been announced that the ADAA has launched a new smart app to enable the reporting of both administrative and financial misconduct. There are several features to the new app, which includes access to the ADAA's existing Wajib reporting platform. The app has been designed to enable members of the community to submit confidential reports for entities under ADAA jurisdiction that have committed violations. The app is designed to (i) prevent violations, (ii) aid the ADAA in the investigation of any reported misconduct, and (iii) promote both the awareness the importance of preserving public resources in Abu Dhabi and shared responsibility. The app ensures that the ADDA stays at the digital technology forefront.

Enhanced cyber security collaboration agreed between Dubai Courts and Moro

Dubai Courts and Moro Hub, a subsidiary of Digital DEWA (the digital arm of Dubai Electricity and Water Authority), have signed a new Memorandum of Understanding (MoU). The aim is to boost collaboration between the two organisations in relation to cyber security and digital transformation.

The MoU was signed by Abdul Rahim Hussain Ahli, CEO, Institutional Support and Communication Sector, Dubai Courts and Marwan Salem Bin Haidar, Vice Chairman - Digital and Group CEO of Digital DEWA. The aim of the MoU is to build a secure and unified technology infrastructure to tackle cybercrimes for society's benefit and it will be a comprehensive legal framework utilising Moro's digital security expertise.

The Dubai Courts has previously committed to its mission of "achieving precise and swift justice and presenting judicial services accessible to all" and its vision to be "pioneering and internationally distinguished courts" and the MoU is an example of that commitment.

Cloud Computing Business Group launched

The Dubai Chamber of Commerce have launched the new Cloud Computing Business Group. The Group's focus will be to promote the development of cloud computing companies and more generally promote the sector to the international community. The Group will tackle industry policy and enable discussion between government entities and the sector to encourage the group and use of cloud computing across industries in Dubai.

Maha AlGargawi, Executive Director of Business Advocacy at Dubai Chambers said, "As one of the most future-ready nations in the world, a cloud-powered advanced digital infrastructure is essential to support Dubai’s goals of fully integrating digital technology into all government operations and plans.

"The setting up of the cloud computing business group is a pillar of this infrastructure as it will encourage transparent conversations between its members, supporting the sector in advocating beneficial policy changes that will in turn enhance its competitiveness."

Abu Dhabi Commercial Bank (ADCB) employees trained in AI and blockchain in banking

A collaboration was put together to train ADCB's employees on AI and blockchain in the banking sector, highlighting the UAE's aim to become a leading player in fields of AI and technology. The training was organised by the Minister of State for Artificial Intelligence, Digital Economy, and Remote Work Applications Office and Chainalysis, which is the leading company in providing blockchain data and analysis to governments, banks, and businesses worldwide. The training was held at Coders HQ, as part of the initiatives "National Programme for Coders".

Saqr Binghalib, Executive Director of the Artificial Intelligence Office, said that "adopting advanced technology is a top priority in the UAE Government aiming to build a sustainable economy based on knowledge and innovation. These programmes align with the National Programme for Coders goals, to empower the government and private sector with digital tools and enhance the talents' educational environment."

Creative Zone joins NextGenFDI initiative

It has been announced by the Ministry of Economy that one of the UAE's largest companies operating in the consulting and business establishment sectors, Creative Zone, has joined the country's NextGenFDI initiative. The parties have signed a Memorandum of Understanding (MoU) and Creative Zone has joined through foreign direct investments. The initiative was launched in July 2022 by the Ministry of Economy to attract digital companies to the UAE and develop next generation tech companies by providing incentives, access, services and commercial real estate. The MoU signed is so that Creative Zone can support the initiative's goals by providing innovative solutions to both investors and entrepreneurs to contribute to their growth within the UAE.

Commenting on the deal, Dr. Thani bin Ahmed Al Zeyoudi, Minister of State for Foreign Trade, said "The agreement further confirms the UAE's intentions to assist and promote emerging businesses and their growth. Through the initiative, Creative Zone will support these objectives by attracting new startups to the UAE and offering a range of business support services, while also boosting their capacity to grow, develop, and support the country's digital business environment".


Nigeria: Bolt launches ride now, pay later service

Bolt, the ride hailing app, has partnered with Nigerian fintech startup, CredPal to launch a ride now, pay later service in Nigeria. Bolt, which has been in Nigeria since 2016, has become the first ride hailing app in Nigeria to launch the deferred payment feature.

Egypt: Telecom Egypt partners with Huawei for Africa's first green tower

Telecom Egypt has partnered with Huawei to install a green telecom tower. The tower has been constructed with alternative materials, including fibre reinforced polymer, which do not require as much carbon dioxide as traditional steel materials to produce. The tower is powered by a solar energy system and includes energy efficiency mechanisms that disable signal amplifiers when not in use.

Central African Republic is Drafting a Cryptocurrency Bill

Central African Republic has set up a 15-member committee tasked with drafting a bill on the use of tokenization and cryptocurrencies. The committee includes experts from five different ministries in the country, including the ministries of mines and geology, town planning and land reform, and justice. The use of cryptocurrencies aims to potentially help eradicate the country’s financial barriers and create a business-friendly environment supported by a legal framework for cryptocurrency usage. This closely follows the country's bill to make Bitcoin a legal tender, which was passed on 24 April 2022, as well as its plans to list its sango crypto coin on exchanges later this year.

Kenya: OpenAI paid under $2 per hour to Kenyan workers to de-toxify ChatGPT

ChatGPT's popularity has rocketed. The powerful artificial intelligence (AI) chatbot can generate text on almost any theme or topic. However, because it had been trained using hundreds of billions of words from the internet, including the darker parts of the web, it was also delivering sexist, violent and racist output. To assist, Kenyan workers were used to identify then feed the AI snippets of unsavoury content. Some Kenyan workers have reported suffering as a result of having to read so much graphic content over the course of their 9 hour shift. The outsourced company, Sama, eventually cancelled its work for OpenAI. 

Additional Information

This publication does not necessarily deal with every important topic nor cover every aspect of the topics with which it deals. It is not designed to provide legal or other advice. Clifford Chance is not responsible for third party content. Please note that English language translations may not be available for some content.

The content above relating to the PRC is based on our experience as international counsel representing clients in business activities in the PRC and should not be construed as constituting a legal opinion on the application of PRC law. As is the case for all international law firms with offices in the PRC, whilst we are authorised to provide information concerning the effect of the Chinese legal environment, we are not permitted to engage in Chinese legal affairs. Our employees who have PRC legal professional qualification certificates are currently not PRC practising lawyers.