This is the property of the Daily Journal Corporation and fully protected by copyright. It is made available only to Daily Journal subscribers for personal or collaborative purposes and may not be distributed, reproduced, modified, stored or transferred without written permission. Please click "Reprint" to order presentation-ready copies to distribute to clients or use in commercial marketing materials or for permission to post on a website. and copyright (showing year of publication) at the bottom.
Subscribe to the Daily Journal for access to Daily Appellate Reports, Verdicts, Judicial Profiles and more...

International Law,
Civil Procedure

Mar. 27, 2026

Litigation differences between the U.S. and China: Strategic insights for counsel

As cross-border disputes involving China increase, U.S. counsel must recognize fundamental differences in discovery, judicial roles, evidentiary rules, precedent, timing and enforcement between U.S. and Chinese litigation systems.

Chong Yu

Chong Yu, admitted to practice law in California, D.C., and China, is a litigation attorney at Shanley APC, with experience in arbitration and a decade of civil and criminal litigation experience in China. She holds an LL.M. from Boston University, an LL.B. from Southwest University of Political Science & Law, and a B.A. from Zhejiang University.

See more...

Litigation differences between the U.S. and China: Strategic insights for counsel
Shutterstock

Cross-border disputes involving China have become increasingly common as U.S. companies expand their operations and commercial relationships overseas. Yet many U.S. counsel approach litigation involving China with assumptions rooted in the American legal system--assumptions that can lead to significant strategic missteps. Understanding the fundamental differences between U.S. and Chinese litigation sy...

To continue reading, please subscribe.
For only $95 a month (the price of 2 article purchases)
Receive unlimited article access and full access to our archives,
Daily Appellate Report, award winning columns, and our
Verdicts and Settlements.
Or
$895, but save $100 when you subscribe today… Just $795 for the first year!

Or access this article for $45
(Purchase provides 7-day access to this article. Printing, posting or downloading is not allowed.)

Already a subscriber?

Enewsletter Sign-up