Our September 16, 2014 client alert, “Brave New World? Recent Challenges Facing Foreign IT Companies in China,” discussed efforts by the Chinese government to enforce heightened network security standards, with a particular focus on the issuance on September 1, 2014 by the Ministry of Industry and Information Technology (“MIIT”) of the Guiding Opinions on Strengthening Network Security in the Telecommunications and Internet Sectors (the “MIIT Opinions”).

A great deal has happened in the six months since the MIIT Opinions were issued. Developments include...