Apple Intelligence’s Unauthorized Rollout in China: A Technical Accident or a Deliberate Regulatory Game?

(By You Yunting) In the early morning of March 31, 2026, Apple rolled out Apple Intelligence to some Chinese users whose iPhones had been updated to iOS 26.4, but the rollout was quickly halted. Today, we will examine the potential legal liabilities involved, the likelihood of regulatory penalties, and whether the rollout was merely a technical accident or a deliberate regulatory game.

I. A Three-Hour Unauthorized Rollout of Apple Intelligence in China

In the early morning of March 31, 2026, some users of China-version iPhones running iOS 26.4 discovered that Apple Intelligence had unexpectedly become available on their devices. The “Siri” entry in the Settings menu was renamed as “Apple Intelligence & Siri”. User feedback indicated that models from Baidu’s ERNIE and Alibaba’s Qwen were integrated into Apple Intelligence in China-version iPhones. For visual analysis functions, some users reported that the image recognition technology associated with Google was invoked.

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Does Sharing a ChatGPT Conversation Link Mean Waiving Your Privacy?

Does Sharing a ChatGPT Conversation Link Mean Waiving Your Privacy?

(By Wang Ting) In late July 2025, the “Share” feature of OpenAI’s ChatGPT triggered a global privacy controversy. Conversation links generated by users were indexed by search engines such as Google, leading to the large-scale exposure of sensitive information, including medical records and trade secrets. Although ChatGPT promptly removed the option that allowed shared conversations to be publicly searchable, debate has continued over whether clicking “Share” should be deemed a voluntary waiver of privacy.

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How Will NVIDIA’s Purchase of Pirated Content to Train AI Be Characterized Under Chinese Law?

(By You Yunting) Recently, a lawsuit filed by U.S. copyright holders against NVIDIA for allegedly using pirated materials to train AI models has attracted significant public attention. According to the complaint, in order to quickly obtain more than 500 terabytes of data, NVIDIA proactively contacted the pirate website Anna’s Archive and paid hundreds of thousands of U.S. dollars to download a large volume of pirated content, including copyrighted books and articles.

Anna’s Archive is one of “shadow libraries” known for their decentralized and anonymous nature, most of which typically provide access to literature in a way that infringes upon its copyright. If the plaintiffs’ allegations are true, it will be a serious blemish on the reputation of NVIDIA, the world’s most valuable company, to have paid a pirate website for content and then been sued by copyright holders. However, the unauthorized use of training data can be considered the “original sin” of nearly all general AI companies. In both China and the United States—the two global leaders in AI technology, numerous lawsuits concerning AI training data have already emerged. We will discuss whether, under Chinese law, NVIDIA’s alleged conduct will be considered breach of law.

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When AI Becomes Involved in Pornographic Content: Is It Unjust to Convict the Developers?

(By You Yunting) It has sparked intense debate recently that the developers of Alien Chat AI were sentenced for its chatting with users about pornographic content. Around the same time, Grok, developed by Elon Musk’s xAI, has drawn global criticism for its “one-click undressing” feature. Although these two cases arose in different jurisdictions and were handled differently, they point to the same core issue: AI compliance management. The following will discuss why AI becomes involved in pornographic content and whether punishing the developers is unjust.

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How Difficult is it for Heygen AI Services that Make Guo Degang Tell English Jokes to Land in China?

(By You Yunting) Recently, many videos of celebrities speaking foreign languages have appeared on the Internet, such as Guo Degang and Zhao Benshan telling English jokes, and Taylor Swift and Donald Trump speaking Chinese, which is actually supported by using AI services of Heygen. I visited Heygen’s website and found that it was not available to domestic users with no WeChat and Alipay in the service payment channel, but in fact Heygen’s founders are two Chinese, both graduating from Tongji University. Today I would like to discuss the formalities Heygen needs to go through in order to have its AI services land in China.

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If Blizzard Changes the Agent of The Legend of Mir II, Can Players’ User Data stored by Netease Be Totally Transferred?

(By You Yunting) Blizzard, a US company recently announced[1] that the license agreement with Netease would expire on 23rd January 2023 and that the parties failed to reach a renewal agreement that conformed to Blizzard’s operational principles and commitments to players and staff members, so it would suspend most of Blizzard’s game services relating to the World of Warcraft, etc. in the Chinese mainland. Let’s discuss this incident and related issues below. Is it possible to renew the agreement? Will the game services be terminated if the agreement renewal failed? If Blizzard changed the Chinese agent, can players’ data be totally transferred?

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How to Send Data in Chinese Concept Share Audit Papers Abroad?

(By You Yunting) China and the US recently signed the Audit Supervision Cooperation Agreement, allowing supervisors and inspectors of the Public Company Accounting Oversight Board (PCAOB) to review audit materials of Chinese companies listed in the US in Hong Kong, including complete audit papers containing all information. According to media reports, Alibaba, JD and Yum China are the first businesses to be audited.[1] Audit papers contain large amounts of data and personal information of domestic users (collectively “data”). I would like to discuss whether the audit paper review by the US parties is outbound data transfer and what procedures should be followed to transfer the data abroad according to Chinese laws.

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Are There Any Differences between WPS and Apple in Scanning Users’ Cloud Data?

(By You Yunting and Wang Ting) According to media reports[1] , the office software WPS recently got involved in a privacy case where one of its users alleged that WPS blocked his local and cloud files without any reasons and caused him unable to use them with the system showing that “they may contain something prohibited and are no longer accessible”. WPS replied that actually, it is the shared link of certain online files that is suspected of violating rules and WPS correspondingly invalidated the access to such link pursuant to laws. However, WPS was still criticized for its scanning users’ data.

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An Overview of Key Points in the Measures for Data Outbound Transfer Security Assessment

(By Wang Hongliang) Just after the latest publication of my article about the compliance concerning outbound transfer of personal information, in which I referred to the Measures for Data Outbound Transfer Security Assessment (Exposure), the exposure version became official regulations on July 7th.

Accordingly, safety evaluation, the strictest way to transfer data abroad became the first one regulated in law. The Measures for Data Outbound Transfer Security Assessment is generally in the context of previous exposure versions. I would like to give a brief explanation of key points in the Rules.

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How will Chinese Regulations on Cross-Border Data Transfers Affect Data Compliance?

(By Gao Tianyi and You Yunting) China’s legal system for dealing with data security and personal information protection standards has been established*, but more detailed rules and standards are in the process of being formulated. This article will mainly discuss the new requirements for, and new changes in, data localization and compliance management regarding cross-border data transfers.

The analysis shows that those who use data from China should keep abreast of changes in policy orientation within the country, in order to avoid potential regulatory risks.

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