Funny when you consider the world owes a lot of AI advancements to both Meta and Google, their open releases really did shift things, feel free to correct me if I'm wrong, especially for China, which as far as I know were not releasing as much in AI as they have been beforehand. I remember when Meta released Llama originally people were speculating about it, but it wound up producing a lot of projects that used it, I'm sure some in China. I know that Perplexity has its own custom model on top of Llama that they use for their default model, and its pretty darn good.
Not sure, but open weights have had their effects. For example, look at Wan 2.2 the last open weights Wan release, still the most powerful Video inference out there, to the level of quality it provides, unfortunately, it went closed source, but before they did, the community had built all sorts of tooling and LoRas on top of it. Nothing comes close for video a year later. Back to llama though, look at all the open models people run offline through their Macs. It definitely had a net positive.
If I'm remembering right, it was weirder than that, as Llama's originally release strategy was sort of bizarre.
You did have to apply for access, but if you met their criteria (basically if you were the right profile of researcher or in government), you got direct access to the model weights, not just an API for a hosted model. So access was restricted, but the full weights were shared.
I believe that the model was leaked by multiple people, some of which didn't work at Meta but had been granted access to the weights.
I don't think it was much of a leak, there was no significant verification--I think .edu email approved automatically. It was probably just there because copyright law related to it was more uncertain then, but they had stronger fair use case with an academic/research gate on it.
I'm curious how this view fits in with BERT or the T5 release which prior to the current LLM craze were the de facto language models for use in pretty much any tasks. Was this a position that would've otherwise grown without the llama release?
> Funny when you consider the world owes a lot of AI advancements to both Meta and Google
Funny how ByteDance kicked both their asses so hard at RecSys algos, they had to go back to the drawing board to meet the newly redefined expectations on the quality of short-form video recommendations.
Also Chinese companies are now single-handedly keeping the future of LLMs open-sourced. DeepSeek being the pinnacle of this. Not only do they publish weights and code, but they publish detailed papers detailing their approach
> After a $75 million fundraising round led by U.S. venture firm Benchmark in May 2025, Manus shut its China offices in July, laying off dozens of employees. It then moved its operations to Singapore.
> It was not immediately clear on what grounds China was seeking the annulment of a deal involving a Singapore-based company and how, if at all, a completed acquisition transaction would be unwound.
> Manus' two co-founders, CEO Xiao Hong and chief scientist Ji Yichao, were summoned to Beijing for talks with regulators in March and later barred from leaving the country, five sources familiar with the matter said.
I suspect this is more of a warning shot to others attempting the same playbook ("Singapore-washing", as I've heard folks call it): the state is watching, and shifting geopolitics means it's in their interest to retain successful talent and entities at home rather than let opposition have them.
If anything, I'm genuinely surprised it took them this long. America's been doing this for decades without much in the way of pushback, so China must feel very confident in its position to use such tactics.
I don't know if America has done anything quite like this. The example I'm looking for is where a company starts in the US but leaves and incorporates outside the US and then the US attempts to block acquisition by a foreign company. Also, the enforcement mechanism while vague seems un-American. America might tax the company upon exit but it wouldn't hold the founders hostage in America. If you have examples I'd be curious.
Famously back in the day Grindr , which had a plot point in the Silicon Valley series . Probably more obscure ones that havent been heard of outside software in the Hard tech space like MotorSich (Ukranian) was being courted by Chinese investment got blocked due to US pressure. And very recently the whole TikTok fiasco.
This chap was arrested in Thailand, extradited, and did a decade in a US prison because he had the audacity of selling weapons from Russia to Colombia. I'm not sure how exactly US law is of any relevance to such transactions...
---
[1] Or, since 2025, just shoot a missile at your boat, with an option for a follow-up salvo if there any survivors. Strangely enough, everyone who has managed to survive both the initial attack, and the double-tap has so far been repatriated to their countries of origin, with no charges filed by the US.
Xiamen Sanan Optoelectronics tried buying Lumileds, blocked again by US. Also Chinese ofc.
Broadcom and Qualcomm deal was also blocked, Broadcom was then Singapore based in process of moving to US I believe... (very sus happened in 2018 too, someone didn't pay Donald enough)
I am certain there must be European examples as well but smaller ofc, AI companies are over valued these days, most acquisitions were never this big in the olden days of pre 2020s...
I know for a fact that most folks don't want to invest in US for this reason other than in public equities or bonds ofc. Private foreign investment in US has been high only due to European pensions and Middle-eastern money going into it.
I don't know about how fair, far, or right it was compared to these were, detaining founders is also not confirmed, but sure let's assume it's true still...
Only difference in US is perhaps foreign folks can sue over it. Sometimes, if they are lucky and if the deal is worth it.
I find it strange people of HN being based in US can be so ill informed of what their country, does to foreign companies but be mad about things foreign companies do to them?
I mean sure rest(96%) of the world doesn't really exist, it's but a myth or a land the better folks of US only want to take value when needed?
Unsure what this comment meant, this has happened before as well btw, these are just post 2010s examples because they are relevant. Russians and US used to do this too, India and US were worse of pre-2000s, Japan and US were at their throats in 1980s, in terms of trade and acquisition...
You don't need to incorporate in the US for this to happen to you. You should look up what happened to Marc Lasus after he founded Gemplus (spoiler, he's on social security while the company the CIA stole from him has $3b revenue) or how Frédéric Pierucci was taken hostage to force the sale of France's nuclear reactors to General Electric. I assume the US does this to all the other countries too.
Being stopped that late is a bit different than the US AFAIK,
but there is certainly the possibility of being stopped from work and (depending how you react) prevented from leaving the US for purely economic inventions:
I find it notable that the US' actual checks on government have worked against expanding the secrecy act further into economic protectionism for favored industries, etc.
You've been all over this this thread responding with the same whataboutist comments claiming America does the same thing. And yet, I'm pretty sure America hasn't held American citizens hostage in order to force them to unwind a sale of a foreign company they founded to a different foreign company.
US absolutely has exit bans on people who break/is being investigated for national security and export control laws, which is what Manus did. Except Americans don't call it hostage taking when they do it.
As another comment mentioned, comparing "employees trying to selling GPUs to an unauthrorized country" and "CEOs selling a company built on national resources to an outside country" is spherical cows levels of comparison.
Another wrong comment doesn't make being wrong less wrong. CEOs/persons trying to sell controlled technology unauthorized for export by origin country. They are direct legal analogs.
Wrong how? It is your comment that is missing the point. The contention isn't whether USA has export control (you are the one who brought it up), it's whether USA has actually prevented a company from being sold overseas by detaining their owners.
US export controls prevent companies from selling controlled tech. If US companies tried o circumvent then they would absolutely be denied, if they did secretly anyway, against, the law of course they'll likely have passport surrendered, i.e. exit ban if flight risk.
Like this isn't complicated, the difference is Manus was full blown retarded enough to transparently circumvent PRC export controls after PRC closed loopholes and politely signalled them to stop, which they didn't, i.e. they broke actual export control laws. Like Manus didn't try to sell, they fucking sold, sign and dotted, despite being told not to, because its against export control laws.
Even US companies rarely this blatantly dense. Americans getting exit banned for selling controlled hardware is LESS serious then what Manus tried to do, i.e. lesser (relative) export control crimes in US getting same treatment.
What are you talking about? Here are the concrete differences:
1. The U.S. has had a long-standing, extremely public policy that you Cannot Sell Nvidia Chips to China since 2022. Supermicro is an American company (based in San Jose, California), and they sold chips to China from 2024-2025, and they got caught, so they were arrested.
2. Manus founders created... an agent harness? And their company was incorporated in Singapore, not in China. And after they sold their Singaporean company to Meta, China decided that selling Singaporean agentic software "violated export controls" (and even the CCP representative couldn't list which supposed control it violated), and detained them all in China and is attempting to force the Singaporean company to unwind the sale.
These are not really comparable. The Supermicro folks are running a company in America and knew ahead of time, for years, that what they were doing violated American export controls. In the case of Manus, they weren't a Chinese company, no one knew they were supposedly violating unwritten export controls, and China decided post-hoc to detain them all and attempt to force the (Singaporean!) company to unwind the sale.
Quite simply this has never happened in corporate America. America is very friendly to corporations and you'd have to be wildly, knowingly in the wrong to get arrested for an M&A deal.
No they're exactly the same, except Manus more retarded than Nvidia and Supermicro.
1. US had wiffle waffle export control policies on what TIER of compute that was exportable. When policies were unclear and compute threshold shifted, Biden admin signalled blank understanding of "presumption of denial" in interregnum while policy figured out exact controls. Nvidia stopped exporting until clarity. That's what due diligence / compliance means.
2. Manus created AI algo in PRC and hence under PRC purview. Fired their PRC team and thought incorporating in Singapore was loophole to transfer PRC controlled tech to US for fat paycheck. PRC was signalled before sale finalizes the Singapore loophole was not some lawfare gotcha to circumvent export controls. This was PRC version of presumption of denial. Ultimately PRC gets to decide if Manus technology CREATED IN PRC is exportable, and under what conditions. PRC company in Singapore fine, using Singapore to transfer to US... not fine. The amount of signals Manus got was similarly clear. PRC writings were talking about art13 of PRC export controls being triggered long before sales. Manus did the retarded and illegal (treasonously) thing and decided to go through with sale and forced PRC hand, when due diligence meant you know, not. AKA Manus did a supermicro but more egregious.
America so friendly they have to export control PRC... prevent US talent from working in PRC semi amirite. Oh wait, turns out when it comes to national security / duo use tech both sides are wildly not business friendly and can play the same geopolitical game. This hasn't happened in America, because quite frankly US businesses are not retarded enough to flaunt US national security instruments due to US gov extraterritorial reach. Manus thought they can do so with PRC who has less extraterritorial = reach, and now PRC slapping them as example. Also no one's arrested yet, just exit ban for ongoing investigation. But would not be surprised if they do end up getting arrested, because they wildly, knowingly in the wrong.
> it's whether USA has actually prevented a company from being sold overseas by detaining their owners.
notably china isnt doing this either: they are barring exit, not detaining, and the reason for barring exit was not reported, so its a stretch to say that its to prevent the sale of the company overseas.
The US:
- makes broad claims of jurisdiction
- has export control, which is listed in the article as a potential reason for blocking the sale, and
- restricts exit from the country when it wants to make sure certain people are available to chat
I dont see whats so exciting about pushing on this specific case. There's an error of, "who's tried to export controlled IP by selling their company to a foreign adversary?"
I dont see what's so exciting about this case that the US definitely absolutely wouldnt take a pretty similar approach to china - bring the CEOs to testify before congress and keep them in the country til the government is satisfied. What's so out of the ordinary that makes this interesting? This is the stuff that goes into work compliance courses.
you might instead want to answer which high tech defense contractor for the US has successfully been bought out by say, iran, china, north korea, or russia, that the US has given the OK on?
I expect there's a lack of data either way. It doesnt come up because people generally move their companies to the US, not out
Although it's true that there's no stated direct link between barring the CEO's exit and Manus's deal, it's not that much of a stretch to say that, specially given China's priors.
Still, I'll concede since that's not what's relevant to me. I'm more curious about the claim that USA would do the same. I can see congress calling the CEO to testify, but keep them in the country until the government is satiafied? How? AFAIK congress has no such power, and the executive may try, and they might be struck down by the courts.
While US has export controls, this wouldn't be a company incorporated, or running, for that matter, in the US (so the Supermicro already doesn't qualify). It would be a company, say, incorporated in the UK. Even if the company started in the US, this, AFAIK, would be unprecedented. Hence the relevance of showing a prior case.
And, make no mistake, I'm not here to say USA is better than China, but these "China is just doing what USA does" claims are getting ridiculous.
It's not their thought, it's core technology created under PRC registered entities before Singapore switcheroo, which makes their IP PRC origin and under purview of PRC according to PRC law. For actual law, article 13 of PRC 2020 export control. Basically catchall provision / blanket ban hammer (for cases of new tech like AI agent), i.e. presumption of denial / ban.
USA has banned the export of some EDA software from Cadence/Synopsys to China.
Therefore the export-control laws of USA obviously make illegal the export of "thoughts".
An even more clear example if that any US citizen who knows classified information or even just a trade secret of some private company and who would tell that information to China would do something illegal.
In this case China argues that the IP has been created in China and its transfer to Singapore does not make it eligible for transfer to USA.
This is the same argument that USA has used multiple times in the past, e.g. for forbidding ASML to sell equipment to China and for forbidding TSMC to have Chinese customers for its advanced fabrication nodes, despite the fact that in both cases the IP that originated in USA some time ago was only a very small part of the products sold by those companies.
If USA may do this, then China is certainly also entitled to do the same. This is not whataboutism, but both countries must be treated equally, either such actions should be forbidden for both under the international laws, or they should be permitted both to do whatever they please.
There is absolutely no doubt that USA is the country who has invented this concept that its laws can be applied outside its territory and they can be applied to things that are the property of non-US entities, as long as they have any component, no matter how small, which has originally been sold to them, directly or indirectly, by an US entity.
I consider any legal interpretation of this kind as abusive and ridiculous, but no American may criticize a foreign country that does nothing else except imitate what USA does.
What examples do you have of the US government doing to CEOs what has happened to people like Jack Ma and many other public figures?
For China, there are so many examples of people doing 180s and being full of contrition after those interventions, it's hard to imagine anything but severe intimidation or worse happening behind closed doors.
I'm totally fine with what-about-ism here; making China a better place to live and do business is out of my jurisdiction and doesn't help me, encouraging the USA to do better will.
It's easy to see how this will play out. The entrepreneurs will get nothing. Most likely everyone else that has been paid (investors, etc) will keep what they received. Whether Meta or the CCP ends up with the proceeds of the entrepreneurs, that's anyone's guess.
Somehow I think there is a real possibility more will happen.
Barring them from leaving the country feels a bit sinister for people who haven't been accused of committing any crimes.
I don't claim to know what's going on outside of what's being reported, but I'm reminded of other individuals who have "stepped out of line" (as determined by Beijing) and were also either barred from the country or mysteriously disappeared for weeks or months at a time only to randomly reappear at some point singing a different tune.
Do you really believe that "activists" and suspected criminals are given the same treatment as some entrepreneurs who just lost their shirts? This feels like an excuse to bring up something that's fundamentally unrelated to the subject at hand, because there are a dozen closer and more useful comparisons to make than Gitmo.
For example how Japan can hold and question people without access to a lawyer, outside of police stations.
This strikes me as a classic case of, “Guy who has only seen The Boss Baby, watching his second movie:
‘Getting a lot of 'Boss Baby' vibes from this!’”
> Barring them from leaving the country feels a bit sinister for people who haven't been accused of committing any crimes.
Pure speculation on my part, but i would be surprised if China didn't have our equivalent of export control laws, not difficult to fabricate a crime and pin it on founders.
Yr parent is new to standard China legal mechanisms and you pivoted off of that to invent a chain of stuff that isn’t real. Are they unfamiliar to us? Yes. But it’s worth speaking to whether the speculation is rational.
They do have export control laws and such, but based on current and past behavior China’s Communist Party doesn’t need those laws to disappear people or create crimes and then make people guilty of said crimes.
Worth mentioning though that this is not how America functions, nor our rule of law.
Not much, none of those cases from the US resulted in disappearing the founders. The US is a nation of laws, no matter how imperfect. Stark contrast to the CCP.
At the end of the day, the process itself, years of investigation, millions in legal fees, frozen assets, destroyed careers is often the punishment regardless of whether charges stick or convictions hold up.
The US is a democracy, and people are given many procedural and substantive rights, even Guantanamo detainees (we can argue if Boumediene had any practical effect, but we wouldn't have seen the same from China).
But Americans are under the impression that what the world sees is what they mostly see -- the domestic side. And to a certain extent, they do thanks to its cultural influence. This democracy/rule of law, however, is completely absent in way it behaves outside its borders and it's now clearer than ever to everyone that the US is the biggest source of instability in the world. More than Russia. Certainly more than China.
Then you probably are not fit to comment on this matter.
I'm sorry to be that blunt but if you don't understand the value of rule of law, the difference in incentives, the consequences of separation of powers, I can't even grasp what kind of perspective you can build. It's genuinely baffling to me.
> Barring them from leaving the country feels a bit sinister for people who haven't been accused of committing any crimes
I don't think it's actually that uncommon in China, especially with high profile people. To China's credit, we often bar people from leaving the country if they're charged with a crime but not convicted of anything. While it's certainly scary and authoritarian, I think it's par for the course in China. Most companies have some amount of CCP representation in them, either on the board or some level of management.
Shouldn't every country be barring people from leaving the country if they've been charged with a crime? At least if there's a good chance they will flee justice.
This seems like a side issue from the question of whether the charges are legitimate.
It's extremely common even without a crime. US block or cancel people with extremely small child support debts (I think like $1000 which is a single missed payment for middle class person) and people with moderate tax debts (I think about $25,000) for instance from getting a passport.
Yes, everyone country does this. You can be barred from travel in a wide range of other circumstances in many other countries.
Every person has a nationalistic solipsism that renders them incapable of understanding events that occur outside of their own country. China and the US are two countries where this tends to be most severe, people outside these countries seem to believe they possess a profound and innate understanding of events there that renders them capable of offering a complete opinion (and, in reality, that opinion will almost always be entirely self-referential, 20% of the comments on this thread seem to be talking about the US).
At a high-level, the characterization of China as a lawless dictatorship is undermined somewhat by the higher levels of crime in almost every other country. You will see this interpretation of China from people in the US who live in places where there are constant, visible signs of crime.
Would that be lower or higher than the number of people who endlessly bang on about "lefties" and or "fascists", "nazis" et al.
I myself find the numbers that engage in political reductionism and sophism to be truly incredible .. easily a double digit percentage of any population, actual billions in total globally.
Wait, is that actually "incredible" though, or just merely "expected"?
> Every country does it. Doing it is a central function of having a government.
You are falling back on whataboutism. This is irrelevant. If we were having a similar debate in the middle ages, you would probably say something like:
> Every church is burning witches and heretics at the stake. Doing it is a central function of having a church.
The CCP has abducted these individuals and is preventing them from leaving the country. This is not ok. You can't justify this by saying "yeah, but they're the government, so it's their right to abduct whoever they want". A government is just a corporation with a bit more power than the others, not some sacred entity that sits above us.
>A government is just a corporation with a bit more power than the others, not some sacred entity that sits above us.
Well yes, a government doesn't need to be sacred to sit above you, it need only have more power. It's legitimacy is conditional on maintaining a monopoly on violence.
If we’re going to descend into pedantry, my statement was normative, not descriptive, as in “I agree this is what a government does, I disagree this is what it _should_ do”.
“Beneath me” is _my_ value judgement that I pass on this government and its appendages as in “it has been weighed in the balance and has been found unworthy”. That this government has more power than me doesn’t make it sit above me as a moral absolute, and it doesn’t magically give it legitimacy.
The government sits above you because it makes you do things under the threat of violence. Why do you stop at the stop sign? because the government reserves the right to hurt you if you don't.
The government's legitimacy comes from it's stick being bigger than yours. It's not sacred, it's not magic. It's a bigger stick. Your value judgement would have weight if your stick was bigger. The guy with the bigger stick decides what you (or Jack Ma) is worthy of.
> The government's legitimacy comes from it's stick being bigger than yours
By the same argument, are Somalian warlords and Mexican drug cartel also legitimate in the territories they control? I don't think "legitimate" is the word you are looking for to describe pure power dynamics, since "legitimate" is imbued with a moralistic judgement (look up is vs ought etc.). But yes, in practice, if I have a gun pointed at my head, I could be forced to do things that go against my judgement (within limits!).
The history of civilization is warlords showing up and saying "Give me 2 bags of wheat from each crop and I won't kill you. Not only that, once I own you, I will fight to make sure the other ensure the other guy can't steal you from me, and that you remain productive."
So long as the warlord can make good on that agreement, you have political order. Over time many abstractions emerge, but backing it all up is the big stick. Now, I'm with you, from a moral standpoint it's all abhorrent. As an anarchist I view civilization to be a hack on the human condition, and I see all states as fundamentally authoritarian.
So it's all just game theory to me. China blocked the Manus acquisition as a matter of national interest. The US also ignores international law on matters on national interest at its own convenience.
If a law is unenforceable is it really a law? Anybody can declare a law. It is only meaningful if it can be enforced.
There are regions of Mexico where cartels hold the monopoly on violence, and the longer they maintain that control the more legitimate they become.
Luckily china has a litany of 3rd world countries land borders surrounding it with porous borders, and in a great deal of them no one who gives too many shits about some poor chinese villager crossing. Americans on the other hand have Canada which for LEO purposes is basically an extension of the US, and Mexico which due to the drug trade and other unique factors mean anyone getting caught jumping the border in either direction is likely to owe the cartel a massive amount of money or some extremely undesirable favors.
I would definitely rather be a trapped Chinese trying to escape than a trapped American.
Surveillance in the PRC is massive and centralized. There's a reason NK fleeing into the PRC plummeted when the PRC decided to stop turning a blind eye.
A valid point. Although PRC citizens have a little easier time explaining why they are in the PRC than North Koreans, and there are hundreds of miles of sparse Chinese border area where no one even knows where China starts/ends and where Pakistan or India begins. Out of places where there is a known border, Myanmar for instance is infamous for porosity.
The reason why NK have stopped is largely either NK enforcement or being caught while in the PRC without permission to reside in the PRC. Both of which are highly mitigated for PRC citizen (PRC citizens can have issues spending time in cities they're not authorized to live in, but less so with merely "visiting" countryside).
This is an exaggeration. But there are things China can do that are legal in the name of national security. I would say it’s just as extreme as what the US would do to Snowden if he came back.
Usually they just threaten the family that stayed in china to enforce compliance. As in visit by police and do a video call. Good old socialist playbook. Guess the CEOs were to workaholic ti be threatened with the mafia methods.
>>> Barring them from leaving the country feels a bit sinister for people who haven't been accused of committing any crimes.
This is standard operating procedure for the CCP. They are a truly ruthless, sinister group who have no scruples about ensuring compliance and using leverage on behalf of Chinese interests. Just look at what happened to Jack Ma.
Outside of immigration issues, you can only be made to surrender your passport if you have been arrested and indicted for a crime, as a part of bail. That power can only be granted by a judge.
China arbitrarily traps people in China without any such thing or any due process whatsoever.
> China arbitrarily traps people in China without any such thing or any due process whatsoever.
What makes you think there's no legal process for blocking nationals from leaving China?It's a very common instrument and in a bunch of countries it's an administrative measure with even less scrutinity than a judicial mandate. Do you consider France or the UK to be a countries without rule of law or due process?
But to the point in the US, for example, the government can just issue a warrant for you as a material witness or flag your passport and then you can't leave; these are hardly due processes and more like legal workarounds to do exactly the same thing; the US has disappeared plenty of people in much more sinister ways than that, however, so I agree that there's no equivalence here: the US is worse.
America is not exactly a shining moral example for the world, particularly these days, but these Chinese apologist takes can be a bit baffling to read at times.
It mostly doesn't make any sense and seems to be motivated by some kind of animus or bigotry. But maybe understandable given the current administration's behavior.
Anyone with a child support order that makes decent money is only one misrecorded or bounced payment away from being ineligible for a passport. The trigger is only 4 digits of USD.
In the US, the Passport Denial Program, since 1998 (other developed countries enacted similar legislation), following the 1992 UN Convention on the Rights of the Child (UNCRC) [2]:
> The Child Support Enforcement Passport Denial Program was enacted as part of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996. While authorized in 1996, the program was jointly implemented by the U.S. Department of State and the Federal Office of Child Support Enforcement in June 1998.
So were these founders found violating a child support order?I'm still unclear on what crime they actually committed and what they're being investigated for.
Is it possible that they are merely pawns in a political dispute between two rival countries?
It's one thing to block an acquisition because you don't want your rival to gain an advantage, an action which is not limited to the CCP.
It's another thing to detain an individual when no crime was committed.
"Missing" (but quite often only due to a clerical misreporting) a payment isn't facially criminal and isn't even established as "violation" without a contempt hearing where you can argue why you didn't actually violate it. So the passport denial is even looser than that.
I'm just pointing out the bar isn't much different except dressed up in a think of the children meme. I'm not justifying either one.
Understood. I'd note that the difference is that with a missed payment, you can simply make that payment (which can be a relatively small one as you noted) and you're free and clear.
With these Chinese founders, I'm not sure it's quite so simple.
The first case makes sense: ex-CIA officer explicitly outing CIA officers. Naturally, the government is going to step in and it's a false equivalence to compare to restricting random citizens.
As for your second case, US schools teach about the perils of McCarthyism. You neglected to link to the subsequent Supreme Court ruling in 1958 overturning the confiscation of the passport over protected speech. Note how long ago that was and how it's taught as a black stain on US history.
Breaking the export rules. Tech workers should be used to the idea of a "Invention Assignment Agreement".
Manus was built in China and all of its development happened there. In order to skirt Chinese review of the deal they tried to close down shop there and move to Singapore.
I don't think China is being unreasonable. I'm sure the US would act exactly the same way if an American tech company raised money from China and then tried to close down in the US and move all of its IP and technology to a different country so that it can be bought out by Alibaba or Bytedance without having to deal with US approval
There is no equivalent exit ban in the US that can be instituted on a whim for regulatory or business disputes. If you want to know more, you can read up on it in this Stanford Journal of International Law publication:
Do you read the news? Whether or not to stop Nippon Steel's acquisition of U.S. Steel was being discussed everywhere. On what basis was that power?
> Nippon Steel's acquisition of U.S. Steel can be stopped by the US President based on a recommendation from the Committee on Foreign Investment in the United States (CFIUS), citing risks to national security under Section 721 of the Defense Production Act.
National security risks. Exactly what China is citing. It's literally the exact same situation.
> Two days ago, President Trump issued an order blocking the $1.3 billion sale of a Portland, Ore.-based company called Lattice Semiconductor to private equity firm Canyon Bridge Capital Partners. The stated rationale for Trump’s order was national security.
All states, by definition, are authorities that demand compliance. You're not saying anything that distinguishes Jack Ma's condition from anyone else's just about anywhere.
I was working at Google at the time. Before Llama, releasing weights was not even worth a discussion.
You did have to apply for access, but if you met their criteria (basically if you were the right profile of researcher or in government), you got direct access to the model weights, not just an API for a hosted model. So access was restricted, but the full weights were shared.
I believe that the model was leaked by multiple people, some of which didn't work at Meta but had been granted access to the weights.
Funny how ByteDance kicked both their asses so hard at RecSys algos, they had to go back to the drawing board to meet the newly redefined expectations on the quality of short-form video recommendations.
Unlike common benchmarks for LLMs.
> It was not immediately clear on what grounds China was seeking the annulment of a deal involving a Singapore-based company and how, if at all, a completed acquisition transaction would be unwound.
> Manus' two co-founders, CEO Xiao Hong and chief scientist Ji Yichao, were summoned to Beijing for talks with regulators in March and later barred from leaving the country, five sources familiar with the matter said.
Will be interesting to see how this plays out.
If anything, I'm genuinely surprised it took them this long. America's been doing this for decades without much in the way of pushback, so China must feel very confident in its position to use such tactics.
Or just order another country to snatch you up.
> https://en.wikipedia.org/wiki/Meng_Wanzhou
She was arrested, and was being extradited from Canada into the United States... Because her Chinese company was doing business with Iran.
> https://en.wikipedia.org/wiki/Viktor_Bout
This chap was arrested in Thailand, extradited, and did a decade in a US prison because he had the audacity of selling weapons from Russia to Colombia. I'm not sure how exactly US law is of any relevance to such transactions...
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[1] Or, since 2025, just shoot a missile at your boat, with an option for a follow-up salvo if there any survivors. Strangely enough, everyone who has managed to survive both the initial attack, and the double-tap has so far been repatriated to their countries of origin, with no charges filed by the US.
For instance US Steel acquisition by Nippon Steel(japanese) is one such example. https://www.bbc.com/news/articles/cx2vz83pg9eo
More examples,
Ant Group(chinese) tried to buy MoneyGram (blocked in 2018) https://www.reuters.com/article/business/us-blocks-moneygram...
Xiamen Sanan Optoelectronics tried buying Lumileds, blocked again by US. Also Chinese ofc.
Broadcom and Qualcomm deal was also blocked, Broadcom was then Singapore based in process of moving to US I believe... (very sus happened in 2018 too, someone didn't pay Donald enough)
https://thediplomat.com/2014/02/india-inc-and-the-cfius-nati... Indian company forced to divest from US tech firm... (2013)
I am certain there must be European examples as well but smaller ofc, AI companies are over valued these days, most acquisitions were never this big in the olden days of pre 2020s...
I know for a fact that most folks don't want to invest in US for this reason other than in public equities or bonds ofc. Private foreign investment in US has been high only due to European pensions and Middle-eastern money going into it.
I don't know about how fair, far, or right it was compared to these were, detaining founders is also not confirmed, but sure let's assume it's true still...
Only difference in US is perhaps foreign folks can sue over it. Sometimes, if they are lucky and if the deal is worth it.
I find it strange people of HN being based in US can be so ill informed of what their country, does to foreign companies but be mad about things foreign companies do to them?
I mean sure rest(96%) of the world doesn't really exist, it's but a myth or a land the better folks of US only want to take value when needed?
Unsure what this comment meant, this has happened before as well btw, these are just post 2010s examples because they are relevant. Russians and US used to do this too, India and US were worse of pre-2000s, Japan and US were at their throats in 1980s, in terms of trade and acquisition...
This is relevant too: https://www.bbc.co.uk/news/world-europe-47765974
https://en.wikipedia.org/wiki/Invention_Secrecy_Act
I find it notable that the US' actual checks on government have worked against expanding the secrecy act further into economic protectionism for favored industries, etc.
Are you trying to push a red herring?
Like this isn't complicated, the difference is Manus was full blown retarded enough to transparently circumvent PRC export controls after PRC closed loopholes and politely signalled them to stop, which they didn't, i.e. they broke actual export control laws. Like Manus didn't try to sell, they fucking sold, sign and dotted, despite being told not to, because its against export control laws.
Even US companies rarely this blatantly dense. Americans getting exit banned for selling controlled hardware is LESS serious then what Manus tried to do, i.e. lesser (relative) export control crimes in US getting same treatment.
1. The U.S. has had a long-standing, extremely public policy that you Cannot Sell Nvidia Chips to China since 2022. Supermicro is an American company (based in San Jose, California), and they sold chips to China from 2024-2025, and they got caught, so they were arrested.
2. Manus founders created... an agent harness? And their company was incorporated in Singapore, not in China. And after they sold their Singaporean company to Meta, China decided that selling Singaporean agentic software "violated export controls" (and even the CCP representative couldn't list which supposed control it violated), and detained them all in China and is attempting to force the Singaporean company to unwind the sale.
These are not really comparable. The Supermicro folks are running a company in America and knew ahead of time, for years, that what they were doing violated American export controls. In the case of Manus, they weren't a Chinese company, no one knew they were supposedly violating unwritten export controls, and China decided post-hoc to detain them all and attempt to force the (Singaporean!) company to unwind the sale.
Quite simply this has never happened in corporate America. America is very friendly to corporations and you'd have to be wildly, knowingly in the wrong to get arrested for an M&A deal.
1. US had wiffle waffle export control policies on what TIER of compute that was exportable. When policies were unclear and compute threshold shifted, Biden admin signalled blank understanding of "presumption of denial" in interregnum while policy figured out exact controls. Nvidia stopped exporting until clarity. That's what due diligence / compliance means.
2. Manus created AI algo in PRC and hence under PRC purview. Fired their PRC team and thought incorporating in Singapore was loophole to transfer PRC controlled tech to US for fat paycheck. PRC was signalled before sale finalizes the Singapore loophole was not some lawfare gotcha to circumvent export controls. This was PRC version of presumption of denial. Ultimately PRC gets to decide if Manus technology CREATED IN PRC is exportable, and under what conditions. PRC company in Singapore fine, using Singapore to transfer to US... not fine. The amount of signals Manus got was similarly clear. PRC writings were talking about art13 of PRC export controls being triggered long before sales. Manus did the retarded and illegal (treasonously) thing and decided to go through with sale and forced PRC hand, when due diligence meant you know, not. AKA Manus did a supermicro but more egregious.
America so friendly they have to export control PRC... prevent US talent from working in PRC semi amirite. Oh wait, turns out when it comes to national security / duo use tech both sides are wildly not business friendly and can play the same geopolitical game. This hasn't happened in America, because quite frankly US businesses are not retarded enough to flaunt US national security instruments due to US gov extraterritorial reach. Manus thought they can do so with PRC who has less extraterritorial = reach, and now PRC slapping them as example. Also no one's arrested yet, just exit ban for ongoing investigation. But would not be surprised if they do end up getting arrested, because they wildly, knowingly in the wrong.
notably china isnt doing this either: they are barring exit, not detaining, and the reason for barring exit was not reported, so its a stretch to say that its to prevent the sale of the company overseas.
The US:
- makes broad claims of jurisdiction - has export control, which is listed in the article as a potential reason for blocking the sale, and - restricts exit from the country when it wants to make sure certain people are available to chat
I dont see whats so exciting about pushing on this specific case. There's an error of, "who's tried to export controlled IP by selling their company to a foreign adversary?"
I dont see what's so exciting about this case that the US definitely absolutely wouldnt take a pretty similar approach to china - bring the CEOs to testify before congress and keep them in the country til the government is satisfied. What's so out of the ordinary that makes this interesting? This is the stuff that goes into work compliance courses.
you might instead want to answer which high tech defense contractor for the US has successfully been bought out by say, iran, china, north korea, or russia, that the US has given the OK on?
I expect there's a lack of data either way. It doesnt come up because people generally move their companies to the US, not out
why is this the hill to die on?
Still, I'll concede since that's not what's relevant to me. I'm more curious about the claim that USA would do the same. I can see congress calling the CEO to testify, but keep them in the country until the government is satiafied? How? AFAIK congress has no such power, and the executive may try, and they might be struck down by the courts.
While US has export controls, this wouldn't be a company incorporated, or running, for that matter, in the US (so the Supermicro already doesn't qualify). It would be a company, say, incorporated in the UK. Even if the company started in the US, this, AFAIK, would be unprecedented. Hence the relevance of showing a prior case.
And, make no mistake, I'm not here to say USA is better than China, but these "China is just doing what USA does" claims are getting ridiculous.
Take any knowledge you’d like with you in your head.
Now think what is going to happen if you export these thoughts from your mouth to your North Korean best friend.
Now the same with Israeli best friend.
Same laws, just one extra entry on the list arbitrarily made by politicians, not independent courts.
Therefore the export-control laws of USA obviously make illegal the export of "thoughts".
An even more clear example if that any US citizen who knows classified information or even just a trade secret of some private company and who would tell that information to China would do something illegal.
In this case China argues that the IP has been created in China and its transfer to Singapore does not make it eligible for transfer to USA.
This is the same argument that USA has used multiple times in the past, e.g. for forbidding ASML to sell equipment to China and for forbidding TSMC to have Chinese customers for its advanced fabrication nodes, despite the fact that in both cases the IP that originated in USA some time ago was only a very small part of the products sold by those companies.
If USA may do this, then China is certainly also entitled to do the same. This is not whataboutism, but both countries must be treated equally, either such actions should be forbidden for both under the international laws, or they should be permitted both to do whatever they please.
There is absolutely no doubt that USA is the country who has invented this concept that its laws can be applied outside its territory and they can be applied to things that are the property of non-US entities, as long as they have any component, no matter how small, which has originally been sold to them, directly or indirectly, by an US entity.
I consider any legal interpretation of this kind as abusive and ridiculous, but no American may criticize a foreign country that does nothing else except imitate what USA does.
When the US does it, you can appeal with an independent court.
When China does it those options don’t exist.
For China, there are so many examples of people doing 180s and being full of contrition after those interventions, it's hard to imagine anything but severe intimidation or worse happening behind closed doors.
Barring them from leaving the country feels a bit sinister for people who haven't been accused of committing any crimes.
I don't claim to know what's going on outside of what's being reported, but I'm reminded of other individuals who have "stepped out of line" (as determined by Beijing) and were also either barred from the country or mysteriously disappeared for weeks or months at a time only to randomly reappear at some point singing a different tune.
Feels like Guantanamo Bay all over again.
Assuming the best of intentions.
https://thediplomat.com/2018/01/michael-caster-on-chinas-for...
For example how Japan can hold and question people without access to a lawyer, outside of police stations.
Pure speculation on my part, but i would be surprised if China didn't have our equivalent of export control laws, not difficult to fabricate a crime and pin it on founders.
Worth mentioning though that this is not how America functions, nor our rule of law.
Not sure we can give any lessons to the world.
But Americans are under the impression that what the world sees is what they mostly see -- the domestic side. And to a certain extent, they do thanks to its cultural influence. This democracy/rule of law, however, is completely absent in way it behaves outside its borders and it's now clearer than ever to everyone that the US is the biggest source of instability in the world. More than Russia. Certainly more than China.
I'm sorry to be that blunt but if you don't understand the value of rule of law, the difference in incentives, the consequences of separation of powers, I can't even grasp what kind of perspective you can build. It's genuinely baffling to me.
“No new US trials are currently planned for the Epstein cases because there has not been credible evidence“
Application of the laws genuinely depends of how much money you have.
We also see it with companies, like if you are OpenAI or Nvidia it suddenly becomes ok to copy pirated works.
Rich people pay damages, poor people go to prison.
Out-of-court settlements are prime definition of such.
Technically, yes the law is followed.
The same with gifts you can officially make to judges in Texas.
Anywhere on this planet where people who have connections can influence the outcome, no matter what is written on a paper, and the US is not exempt.
I don't think it's actually that uncommon in China, especially with high profile people. To China's credit, we often bar people from leaving the country if they're charged with a crime but not convicted of anything. While it's certainly scary and authoritarian, I think it's par for the course in China. Most companies have some amount of CCP representation in them, either on the board or some level of management.
This seems like a side issue from the question of whether the charges are legitimate.
Every person has a nationalistic solipsism that renders them incapable of understanding events that occur outside of their own country. China and the US are two countries where this tends to be most severe, people outside these countries seem to believe they possess a profound and innate understanding of events there that renders them capable of offering a complete opinion (and, in reality, that opinion will almost always be entirely self-referential, 20% of the comments on this thread seem to be talking about the US).
At a high-level, the characterization of China as a lawless dictatorship is undermined somewhat by the higher levels of crime in almost every other country. You will see this interpretation of China from people in the US who live in places where there are constant, visible signs of crime.
Team coca-cola and team pepsi are both evil and illegitimate.
The number of, presumably, left-wing people who advocate for the most extreme forms of libertarianism is truly incredible.
I myself find the numbers that engage in political reductionism and sophism to be truly incredible .. easily a double digit percentage of any population, actual billions in total globally.
Wait, is that actually "incredible" though, or just merely "expected"?
You are falling back on whataboutism. This is irrelevant. If we were having a similar debate in the middle ages, you would probably say something like:
> Every church is burning witches and heretics at the stake. Doing it is a central function of having a church.
The CCP has abducted these individuals and is preventing them from leaving the country. This is not ok. You can't justify this by saying "yeah, but they're the government, so it's their right to abduct whoever they want". A government is just a corporation with a bit more power than the others, not some sacred entity that sits above us.
Well yes, a government doesn't need to be sacred to sit above you, it need only have more power. It's legitimacy is conditional on maintaining a monopoly on violence.
“Beneath me” is _my_ value judgement that I pass on this government and its appendages as in “it has been weighed in the balance and has been found unworthy”. That this government has more power than me doesn’t make it sit above me as a moral absolute, and it doesn’t magically give it legitimacy.
The government's legitimacy comes from it's stick being bigger than yours. It's not sacred, it's not magic. It's a bigger stick. Your value judgement would have weight if your stick was bigger. The guy with the bigger stick decides what you (or Jack Ma) is worthy of.
By the same argument, are Somalian warlords and Mexican drug cartel also legitimate in the territories they control? I don't think "legitimate" is the word you are looking for to describe pure power dynamics, since "legitimate" is imbued with a moralistic judgement (look up is vs ought etc.). But yes, in practice, if I have a gun pointed at my head, I could be forced to do things that go against my judgement (within limits!).
So long as the warlord can make good on that agreement, you have political order. Over time many abstractions emerge, but backing it all up is the big stick. Now, I'm with you, from a moral standpoint it's all abhorrent. As an anarchist I view civilization to be a hack on the human condition, and I see all states as fundamentally authoritarian.
So it's all just game theory to me. China blocked the Manus acquisition as a matter of national interest. The US also ignores international law on matters on national interest at its own convenience.
If a law is unenforceable is it really a law? Anybody can declare a law. It is only meaningful if it can be enforced.
There are regions of Mexico where cartels hold the monopoly on violence, and the longer they maintain that control the more legitimate they become.
I would definitely rather be a trapped Chinese trying to escape than a trapped American.
The reason why NK have stopped is largely either NK enforcement or being caught while in the PRC without permission to reside in the PRC. Both of which are highly mitigated for PRC citizen (PRC citizens can have issues spending time in cities they're not authorized to live in, but less so with merely "visiting" countryside).
This is standard operating procedure for the CCP. They are a truly ruthless, sinister group who have no scruples about ensuring compliance and using leverage on behalf of Chinese interests. Just look at what happened to Jack Ma.
It's standard procedure in every country for some investigations.
Outside of immigration issues, you can only be made to surrender your passport if you have been arrested and indicted for a crime, as a part of bail. That power can only be granted by a judge.
China arbitrarily traps people in China without any such thing or any due process whatsoever.
What makes you think there's no legal process for blocking nationals from leaving China?It's a very common instrument and in a bunch of countries it's an administrative measure with even less scrutinity than a judicial mandate. Do you consider France or the UK to be a countries without rule of law or due process?
But to the point in the US, for example, the government can just issue a warrant for you as a material witness or flag your passport and then you can't leave; these are hardly due processes and more like legal workarounds to do exactly the same thing; the US has disappeared plenty of people in much more sinister ways than that, however, so I agree that there's no equivalence here: the US is worse.
This has historically not been the case, for example https://en.wikipedia.org/wiki/Haig_v._Agee and https://en.wikipedia.org/wiki/Paul_Robeson
> The Child Support Enforcement Passport Denial Program was enacted as part of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996. While authorized in 1996, the program was jointly implemented by the U.S. Department of State and the Federal Office of Child Support Enforcement in June 1998.
https://en.wikipedia.org/wiki/Child_support#Enforcement
[1]: "The [US] Child Support Enforcement Passport Denial Program" https://www.congress.gov/crs-product/IN12660
[2]: https://en.wikipedia.org/wiki/U.S._ratification_of_the_Conve...
Is it possible that they are merely pawns in a political dispute between two rival countries?
It's one thing to block an acquisition because you don't want your rival to gain an advantage, an action which is not limited to the CCP.
It's another thing to detain an individual when no crime was committed.
I'm just pointing out the bar isn't much different except dressed up in a think of the children meme. I'm not justifying either one.
With these Chinese founders, I'm not sure it's quite so simple.
As for your second case, US schools teach about the perils of McCarthyism. You neglected to link to the subsequent Supreme Court ruling in 1958 overturning the confiscation of the passport over protected speech. Note how long ago that was and how it's taught as a black stain on US history.
https://en.wikipedia.org/wiki/Kent_v._Dulles
They seem to be the poster children for a flight risk.
Manus was built in China and all of its development happened there. In order to skirt Chinese review of the deal they tried to close down shop there and move to Singapore.
I don't think China is being unreasonable. I'm sure the US would act exactly the same way if an American tech company raised money from China and then tried to close down in the US and move all of its IP and technology to a different country so that it can be bought out by Alibaba or Bytedance without having to deal with US approval
"Legal Strategy for Commercial Hostage-taking and Business Exit Bans" https://law.stanford.edu/wp-content/uploads/2024/08/SJIL_60-...
What a mic drop.
> Nippon Steel's acquisition of U.S. Steel can be stopped by the US President based on a recommendation from the Committee on Foreign Investment in the United States (CFIUS), citing risks to national security under Section 721 of the Defense Production Act.
National security risks. Exactly what China is citing. It's literally the exact same situation.
EDIT: In fact, the US regularly stops acquisition of US companies by China https://hvmilner.scholar.princeton.edu/sites/g/files/toruqf2...
https://hvmilner.scholar.princeton.edu/sites/g/files/toruqf2...