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Legislation
CAC Publishes Notification Guidelines for Security
Assessment on Cross-border Data Transfer (1st Edition)
On August 31, 2022, in order to guide data handlers to declare
outbound data transfer security assessment orderly, the Cyberspace
Administration of China (“CAC“) has
promulgated the Notification Guidelines for Security Assessment
on Cross-border Data Transfer (the 1st Edition)，which
explains the specific requirements on the declaration method,
declaration process and declaration materials for outbound data
transfer security assessment. 1
SPC, SPP and MOPS Jointly Publish Opinions on Several
Issues Concerning the Application of Criminal Procedures for Cyber
Crime Cases
On August 30, the Supreme People’s Court
(“SPC“), the Supreme People’s
Procuratorate (“SPP“), and the Ministry
of Public Security (“MOPS“) jointly
publishes the Opinions on Several Issues Concerning the
Application of Criminal Procedures for Cyber Crime Cases. The
main contents of the opinion include: (i) further regulating the
jurisdiction of cyber-crime cases; (ii) further regulating the
taking of evidence in cyber-crime cases; (iii) further regulating
the examination of evidence in cyber-crime cases; and (iv) further
regulating the handling of property involved in cyber-crime cases.
2
Shanghai Economy and Information Technology Commission
Publishes Measures for the Administration of Information
Infrastructure in Shanghai (Exposure Draft)
On August 29, to promote the construction of information
infrastructure, safeguard the security of information
infrastructure, and support the development of informatization and
digital transformation needs in Shanghai, the Shanghai Economy and
Information Technology Commission formed the Measures for the
Administration of Information Infrastructure in Shanghai (Exposure
Draft) which is now open to public comments. 3
Department of Industry and Information Technology of
Guangdong Province Issues Guide to Building Chief Data
Officers for Guangdong Enterprises
On August 24, to build a high-end talent team for data
management, fully exploit the value of data resources, promote the
digital transformation of enterprises, and facilitate the
high-quality development of the province’s digital economy, the
Department of Industry and Information Technology of Guangdong
Province notified that the Guide to Building Chief Data
Officers for Guangdong Enterprises was issued to all
administrative departments in Guangdong Province. 4
MOT Publishes Administrative Measures for Protection
on Critical Information Infrastructure on Highway and Waterway
(Draft for Comment)
On August 23, to regulate the management of the protection of
critical information infrastructures
(“CII“) on highways and waterways and to
implement the responsibility for CII protection, the Ministry of
Transport (“MOT“) drafted the
Administrative Measures for Protection on Critical Information
Infrastructure on Highway and Waterway (Draft for Comment)
which is now open to public comments. 5
National Health Commission and Other Departments Jointly
Publishes Administrative Measures for Cybersecurity of Medical
and Health Institutions
On August 8, to guide healthcare institutions to strengthen the
cyber security management, the National Health Commission, the
National Administration of Traditional Chinese Medicine and the
National Administration of Disease Prevention and Control
formulated the Administrative Measures for Cybersecurity of
Medical and Health Institutions.6
Enforcement Authority
Personal Information Protection Forum of China Internet
Civilization Conference in 2022 held in Tianjin
On August 29, 2022, the Personal Information Protection Forum of
China Internet Civilization Conference in 2022 was held in Tianjin.
With the theme of “Better personal information protection,
better internet civilization”, the forum aims to focus on
personal information protection in the process of building internet
civilization, showcase theoretical achievements and innovation in
personal information protection, discuss and exchange cooperative
governance mechanisms, and promote the rule of law in personal
information protection in the construction of digital civilization.
7
China to Establish Authoritative and Trusted Digital
Identity Blockchain System
On August 25, “Research and application of digital identity
blockchain technology based on legal certifications” which is
in the “Bounty List” of National Key Research and
Development Program, led by the Institute I of the Ministry of
Public Security (“MOPS“), was officially
launched and implemented. As the underlying blockchain platform,
“Chang’an Chain” will support the construction of a
high-performance distributed digital identity structure and provide
technical support for the construction of a credible digital
identity system in China. 8
Shanghai Data Exchange Takes Lead of Setting up Digital
Asset Section
On August 24, the “Shanghai City Digital Transformation
Experience Week” was officially held. At the event, as the key
infrastructure for Shanghai’s digital transformation and
important achievement in the construction of data element market,
Shanghai Data Exchange was the first in China to set up digital
asset section, reconstructing the digital asset system and creating
a new model of deep integration between digital assets and the real
economy. On the same day, the Shanghai Data Exchange, together with
Huayi Group’s state-owned brand “WARRIOR” and the
first issuance platform of digital assets “Bilibili”,
premiered the digital asset “WARRIOR DESIGN – First
Year”. 9
Shanghai Holds Meeting on Data Classification and Grading
and Formulating Catalogs of Important Data by Pilot Working
Group
On August 24, Shanghai cyberspace administration and the General
Office of the Municipal Government (“pilot working
group“) organized about 50 people of 16 pilot
organizations to hold a meeting on data classification and grading
and formulating catalogs of important data. The meeting introduced
the plan of the pilot working and mentioned specific work
requirements. In the next step, the pilot working group will
further strengthen the co-ordination to enhance the level of data
security protection in the city. 10
Guangdong Provincial Postal Administration Joins Relevant
Departments to Supervise Governance of Personal Information
Security in Postal and Express Sector
On August 24, the Guangdong Provincial Postal Administration
joins the Provincial Public Security Department and Provincial
Cyberspace Administration, carried out a provincial supervision and
inspection in Guangzhou on the in-depth promotion of the governance
of personal information security in the postal and express sector.
The Steering Group held a meeting to listen to the report on the
governance of personal information security from major express
enterprises such as Sto Express Co., Ltd., YTO Express Group Co.,
Ltd., ZTO Express Co., Ltd., and to deploy the next stage of work.
11
MIIT Organized More than 300 Industrial Enterprises
Conducts Data Security Management Pilots
On August 19, Shaoqing Zhou, the top level inspector of the
Ministry of Industry and Information Technology
(“MIIT“), announced at
a news conference that the MIIT has been in the industrial region,
organizing more than 300 industrial enterprises in 15 provinces to
carry out data security management pilots and keep exploring the
construction of data management governance model. 12
CAC States More than 20 Enterprises to Go Public Abroad
Declared Cybersecurity Review
On August 19, the CAC stated: to meet the requirements of the
Cybersecurity Law of the People’s Republic of China
(“CSL“), the Data Security Law of
the People’s Republic of China
(“DSL“), the Personal Information
Protection Law of the People’s Republic of China
(“PIPL“) and other regulations, the
relevant departments of the CAC have revised the Cybersecurity
Review Measures. Since the revision and implementation of
Cybersecurity Review Measures on February 15, 2022, more
than 20 companies planning to go public abroad have declared to the
Office of Cybersecurity Review. 13
CAC Announces Filing Information on Internet Information
Service Algorithm System
On August 12, according to the Administrative Provisions on
Algorithm Recommendation for Internet Information Services,
the CAC announces the names and filing numbers of domestic Internet
information service algorithms, and the relevant information can be
checked through the internet information service algorithm filing
system. 14
6 Cities to Carry out Pilots of High-Precision Maps for
Intelligent Connected Vehicles
On August 2, the Ministry of Natural Resources issued the
Notice on Relative Work to the Pilots of High-Precision Maps
for Smart Vehicles, in which six cities, namely Beijing,
Shanghai, Guangzhou, Shenzhen, Hangzhou and Chongqing, will conduct
the action to form a technical path and demonstration model for the
safe application of maps related to autonomous driving that can be
replicated and promoted nationwide. 15
CAC Publishes Report of the Digital China Development
(2021)
On August 2, to implement the important deployment of the Party
Central Committee and the State Council on building Digital China,
and to further implement the strategic plans in digitalization, the
CAC, together with relevant departments, tracked and monitored the
digital development of various regions and sectors, carried out the
assessment of digital development in China, and completed the
Report of the Digital China Development (2021). The report
summarizes the remarkable achievements made in the construction of
Digital China since the 19th Communist Party of China National
Congress and the important progress and effectiveness in 2021,
assesses the level of digital development in various regions in
2021, and provides an outlook for the construction of Digital China
in 2022. 16
Enforcement Cases
MIIT Notifies 47 APPs and SDKs Infringing on Rights of
Users
On August 26, 2022, the MIIT organized third-party testing
agencies to review mobile APPs and SDKs that are of concern to the
public, such as hotels and restaurants, applications for minors,
and put forward rectification requirements for a total of 227 APPs
(SDKs) found to be infringing on users’ rights and notified 47
APPs (SDKs) that had not completed rectification as required.
17
Shanghai Communications Administration Notifies 127 APPs
Infringing Users Rights and Interests
On August 22, in accordance with the PIPL, the
CSL, the Telecommunications Regulations, and the
Provisions on Protecting the Personal Information of
Telecommunications and Internet Users, etc., the Shanghai
Communications Administration organized third-party testing
agencies to review APPs for infringement of rights of users and
ordered 127 APPs related to “collecting personal information
in violation of regulations”, “illegal use of personal
information” and “deceiving and misleading users to
download Apps” with rectification requirements.
18
CAC Interviews 3,491 Websites and Platforms and Fines 283
Websites in 1st Half of 2022
On August 19, Yibing Niu, the news spokesman of the CAC,
announces that to promote the rule of law in cyber region, the
national network system in the first half of 2022, interviewed
3,491 websites legally, fined 283 websites, suspended the functions
or updates of 419 websites, removed 177 mobile applications,
canceled the license or recordation, and closed 12,292 illegal
websites in conjunction with the telecommunications
administrations. 19
Shanghai Communications Administration Notifies 18
Companies Failed to Implement Rectification on Cybersecurity
Protection on Schedule
On August 15, the Shanghai Communications Administration
inspected 6 companies and found that they had failed to implement
their responsibilities for the management of cybersecurity
protection. At the same time, the 22 rated systems of 18 companies
failed to implement the rectification requirements of communication
network security protection management on schedule. The
notification states that the above-mentioned companies should
implement the rectification work by 15 September 2022 (within 30
days from the date of publication of the notification).
20
Jiangsu Launches Cybersecurity Operation to Identify Data
Security Risks in 3 Types of Enterprises
On August 11, the special action of cyber and data security
review in telecommunication industry in Jiangsu Province was
officially launched. The target objects of this action involve
three types of enterprises, including four basic telecommunication
enterprises, 100 provincial Internet enterprises and 200 industrial
Internet enterprises. At the end of the review, the Provincial
Communications Administration will organize comments, notify
problems, and supervise rectification. 21
Shanghai Consumer Council States Banking APPs Shall Collect
Users’ Data on “Health and Fitness” in Clearer and
More Explicit Approach
On August 9, China’s Industrial Bank
(“CIB“) responded to the topic of
“the CIB APP monitors the heart rate and step count of
users”, stating that the permission is not opened by default,
and only when the customer intends to participate in the
“Walk” activity will the application for the relevant
permission appear. The information will only be obtained with the
customer’s consent. If the customer does not agree, it does not
affect the use of other functions of the CIB APP. The Shanghai
Consumer Council pointed out that although users’ disagreement
will not affect the online financial services of the CIB APP, it
hoped that CIB would clearly and explicitly inform consumers of the
purpose of requesting data on their health status and fitness
activities, which could otherwise easily lead to questions.
22
CAC Concentrates on Rectifying Chaos of Speculation
Involving Virtual Currencies
On August 9, the CAC stated: in accordance with the spirit of
the Notice on Further Preventing and Dealing with Speculation
Risks in Virtual Currency Trading, the CAC has urged and
guided major websites to effectively implement their main
responsibilities, continue to maintain a high pressure against
speculation in virtual currency trading, and increase efforts in
self-correction of information and accounts on inducement of
investment in virtual currency. The website platforms, such as Sina
Weibo and Baidu, closed 12,000 offending accounts and cleaned up
more than 51,000 pieces of offending information according to their
user agreements. 23
CAC Publishes Typical Cases of Telecommunication and Cyber
Fraud Involving Minors
On August 9, the officers of the CAC stated based on the action
brought by CAC and the MOPS during the summer holiday including
cleaning up the online fraud-related harmful information,
accurately reminding the potentially deceived people, strictly
punishing the lawbreakers, maintaining the safety of minors’
property and mental health, that the websites fulfill their
responsibilities of information management, and play an important
role in disposing fraud-related harmful information, and rectifying
telecommunications and cyber fraud. But at the same time, some
websites and platforms fail to recognize their responsibilities and
improve their system and mechanism. To improve people’s ability
to know and prevent fraud, especially minors, therefore some
typical cases are published. 24
CBIRC Launches Special Rectification to Change Banking and
Insurance Institutions’ Infringement of Rights and Interests of
Personal Information
On August 8, the China Banking and Insurance Regulatory
Commission (“CBIRC“) issued the
Notice on Special Rectification of Irregularities of Banking
and Insurance Institutions Infringing upon Personal Information
Rights and Interests to all CBIRC local bureaus, banking and
insurance institutions, etc., requiring a comprehensive inventory
and investigation of problems and loopholes in the protection of
personal information in the banking and insurance industry,
in-depth rectification of the chaos of infringing on the rights and
interests of consumers’ information, and supervising banking
and insurance institutions to establish or upgrade the working
mechanism for the protection of consumers’ personal
information, etc. 25
Zhejiang Communications Administration Announces APPs that
Violate Rights and Interests of Users
On August 3, the Zhejiang Communications Administration stated
that it had commissioned third-party testing agencies to test 50
mobile phone applications, of which 42 APPs had problems related to
“collecting personal information in violation of
regulations”, “collecting personal information beyond the
scope”, “illegal use of personal information”,
“forcing users to use directional push functions”, etc.
The Zhejiang Communications Administration has ordered in writing
that the problematic APPs and related enterprises rectify the
situation within a certain period. 26
Police of Haizhu City in Guangzhou Punishes 21 Companies
for Using APPs to Collect Personal Information in Violation of
Regulations
On August 3, to further strengthen the protection of personal
information, the police of Haizhu City in Guangzhou concentrated on
special rectification activities for collection of personal
information in violation of regulations by APPs to carry out
comprehensive enforcement reviews on organizations and enterprises
providing mobile Internet services, and punished 21 enterprises for
their non-compliance in accordance with the law. 27
MIIT Announces Quality of Telecommunications Services in
2nd Quarter of 2022: Tested 570,000 APPs and Ordered Rectification
on 358 APPs
On August 2, in accordance with the Telecommunications
Regulations of the People’s Republic of China, the MIIT
notified the quality of the telecommunications services in the
second quarter of 2022. Among them, the MIIT organized testing of
570,000 APPs, ordered 358 APPs to be rectified and publicly
notified 121APPs. 28
Guangdong Communications Administration Conducts
Cybersecurity Review on Xiaopeng Automotive and GAC Toyota’s
Internet of Vehicles
On August 2, to implement the requirements of the CSL,
and the Several Provisions on Automotive Data Security
Management (for Trial Implementation), etc., according to the
unified work deployment of the MIIT, Guangdong Communications
Administration organized experts from the China Center for
Information Industry Development
(“CCID“) and China Academy of
Information and Communications Technology
(“CAICT“), to carry out a week-long
cybersecurity review on Guangzhou Xiaopeng Automotive Technology
Co., Ltd. and GAC Toyota Motor Co., Ltd. The review focused on two
major aspects: one is the safety of the Internet of Vehicles
service platform, and the other is the data safety of Internet of
Vehicles. 29
Shanghai Strengthens Control on APPs With More Than 5
million Downloads/Installs and to Adopt Stricter Regulations From
August
On August 1, in continuation of the Notice of the Ministry
of Industry and Information Technology on Launching the Action for
Improvements to the Perception of Information and Communications
Services issued in November 2021, the Shanghai Communications
Administration will focus on APPs (including new forms such as
rapid applications and mini programs) with more than 5 million
downloads/installations within a single domestic application
market. In fact, mobile APPs have been the subject of regulations
several times in recent years, with the Administrative
Provisions on Mobile Internet Applications Information
Services having been released in June 2022 and coming into
effect from August 1, 2022. 30
Courts Litigation
Hangzhou Internet Court Releases “10 Typical Cases of
Data and Algorithms” and “10 Typical Cases of Personal
Information Protection” on its 5th Anniversary
In August, 2022, Hangzhou Internet Court selected 10 typical
cases closely related to data or algorithms to be released on the
5th anniversary of its establishment, which involved areas such as
the legal attributes and the protection of data products, and the
boundary of legality of commercial use of public data. To focus on
the highlighted issues and public concern regarding personal
information protection, Hangzhou Internet Court selected and
released 10 typical cases closely related to personal information
protection as well. One of the typical cases is that a short video
APP operated by a technology company infringed the personal
information of massive unspecified children. On 11 March 2021, the
Hangzhou Internet Court made a civil mediation, in which the
technology company stopped the infringement, apologized, and
compensated damages of RMB 1.5 million for the reconstruction of
children’s personal information protection, and rectified the
short video APP platform. 31
Court Rules Use of “Crawler” Software by 9 People
to Obtain Mobile Phone Numbers of Operators Constitutes Crime of
Infringement Upon Citizens’ Personal Information
Since March 2021, Mr. Zhao and others wrote crawler tools and B
software for profit, and used the software to illegally obtain the
personal mobile phone numbers of operators of newly registered
companies in the region by accessing the websites of industrial and
commercial bureaus. On August 19, the court held that Mr. Zhang and
eight others sold personal information of citizens to others in
violation of the relevant regulations, and their acts have
constituted the crime of infringement upon citizens’ personal
information. 32
Court Rules Disclosure of Personal Information in
Indictment without Consent Constitutes Infringement
On August 16, the court responded to a case in which a property
owner sued the committee of property owners for infringement of
privacy rights, as to whether the disclosure of personal
information in indictments without consent constitutes
infringement. The court held that personal information such as
identity card number, date of birth, place of residence, telephone
number and other personal information contained in the indictment
is sensitive information, which is related to peace of personal
life and may endanger personal and property safety if leaked or
misused, and is private and confidential information, which shall
be included in the scope of privacy right protection, and
therefore, the above-mentioned behavior constitutes infringement of
privacy right. 33
Court Rules Sale of Personal Information to Others
Constitutes Crime of Infringement Upon Citizens’ Personal
Information and Liable for Public Compensation
On August 10, Jiangshan Intermediate People’s Court of
Zhejiang Province concluded a case of public interest civil
litigation collateral to a criminal proceeding for infringement of
citizens’ personal information. The defendant, Li, was
sentenced in the first instance to seven months’ imprisonment,
suspended for one year and one month, confiscated the illegal
proceeds and fined for agreeing to a friend’s request to sell
the property owner’s information obtained when joining a real
estate company for profit, while the court ordered Li to bear
public compensation of RMB 16,500 and to publicly apologize in the
media above the municipal level. 34
SPP Releases Typical Cases Related to Data Compliance of
Internet Companies
On August 10, the SPP released the third batch of typical cases
related to data compliance of internet companies, which is also the
first time that typical cases were released after the SPP deployed
nationwide pilots of data compliance for enterprises involved in
cases in April. The typical cases were selected from the cases
recently completed by the procuratorial authorities, taking into
full consideration the characteristics of different types of
enterprises, including large, medium-sized, and small and micro
enterprises. The cases are not only including the specific
compliance system for large and medium-sized enterprises, but also
include the simplified compliance system for small and micro
enterprises, making the typical cases more representative.
35
Dentons Team
Dentons Holds Off-line Sharing Conference on Data
Compliance in Beijing
On August 10, 2022, under the background of the introduction of
the Security Assessment Measures for Cross-border Transfer of
Data, Provisions on Standard Contracts for Cross-border
Transfer of Personal Information(Draft for Comment)
and the Cybersecurity Standards Practice Guide
——Security Certification Standard for Cross-border
Processing Activities of Personal Information, Dentons lawyers
held an offline seminar in Beijing on the theme of “New
Regulations on Cross-border Transfer of Data: Interpretation of
Legislation and Response in Practice”, with guest speakers
including Ke Xu, Executive Director of the Digital Economy and
Legal Innovation Research Center of the University of International
Business and Economics, Jet Deng, Senior Partner of Dentons
Beijing, and Ken Dai, Partner of Dentons Shanghai.36
Footnotes
1 http://www.cac.gov.cn/2022-08/31/c_1663568169996202.htm
2
https://www.spp.gov.cn/spp/xwfbh/wsfbt/202208/t20220830_575301.shtml#1
3
http://www.sheitc.sh.gov.cn/gg/20220817/a15a0885a77d4dbca51a7e740d8a926c.html
4
https://mp.weixin.qq.com/s/G9k4AjDwUIVhJF8PpE8HAg?scene=25#wechat_redirect
5
https://www.mot.gov.cn/yijianzhengji/dangqianzhengji/202208/t20220823_3669717.html
6
http://www.nhc.gov.cn/guihuaxxs/s10743/202208/50e2ef41b7554ae894053bcac32b79f0.shtml
7 http://www.cac.gov.cn/2022-08/31/c_1663567296562726.htm
8
https://mp.weixin.qq.com/s/PaK0I5kCIEF5v3dfvXSRbg?scene=25#wechat_redirect
9
https://mp.weixin.qq.com/s/eMRbEJQzAwnk_TdYz_OYCA?scene=25#wechat_redirect
10
https://mp.weixin.qq.com/s/RTPL2Lry8wpLtBKEdO8giw?scene=25#wechat_redirect
11
https://www.spb.gov.cn/gjyzj/c100015/c100016/202208/c65adf1ca12f45a396f760e2606f965f.shtml
12 https://news.youth.cn/gn/202208/t20220819_13934128.htm
13
http://news.cyol.com/gb/articles/2022-08/19/content_Oo6KmIWya.html
14 http://www.cac.gov.cn/2022-08/12/c_1661927474338504.htm
15
https://www.mnr.gov.cn/dt/ywbb/202208/t20220802_2743109.html
16 http://www.cac.gov.cn/2022-08/02/c_1661066515613920.htm
17
https://mp.weixin.qq.com/s/1ZdnivGpVGJGG7_nw7EbAA?scene=25#wechat_redirect
18
https://mp.weixin.qq.com/s/dwlCkGjeRQRGf23xyvT7fw?scene=25#wechat_redirect
19 https://china.huanqiu.com/article/49IgeRcZHNK
20 https://china.huanqiu.com/article/49FiYxGNxh8
21 http://js.people.com.cn/n2/2022/0812/c360303-40077241.html
22
https://mp.weixin.qq.com/s/prtw-ntdgRB7M8Xf4hLHHg?scene=25#wechat_redirect
23
https://mp.weixin.qq.com/s/gpOkKXocfzDBE8vhNQOQDA?scene=25#wechat_redirect
24 http://www.cac.gov.cn/2022-08/08/c_1661598811963807.htm
25 https://m.thepaper.cn/newsDetail_forward_19392283
26
https://zjca.miit.gov.cn/zwgk/tzgg/art/2022/art_16c19b470d0b4c65931f4a7f81653029.html
27
https://mbd.baidu.com/newspage/data/landingsuper?third=baijiahao&baijiahao_id=1740151647888599748&wfr=spider&c_source=kunlun&p_tk=4447jq4tX%2BFbSBp%2Bn58q5Q4q6EhuSebcZGmf8pYR7nyzXUDO2Ezx
%2FM7yaySqp5gsA6Iq1zmlVDI4rpxcMhto8BZJutzT%2FSo7NnPXTG07IIcIFivBwClu%2FEoMlvvpAZ9lUW17oYLNHbXgZ4eagugSLyXxDQ%3D%3D&p_timestamp=1661851804&p_sign=a196fbb725bc63b14cc3d6f6ffde2100&p
_signature=157ed6d423fe25b98615e0cae88f18df&__pc2ps_ab=4447jq4tX%2BFbSBp%2Bn58q5Q4q6EhuSebcZGmf8pYR7nyzXUDO2Ezx%2FM7yaySqp5gsA6Iq1zmlVDI4rpxcMhto8BZJutzT%2FSo7NnPXTG07IIcIFivBwClu%
2FEoMlvvpAZ9lUW17oYLNHbXgZ4eagugSLyXxDQ%3D%3D%7C1661851804%7C157ed6d423fe25b98615e0cae88f18df%7Ca196fbb725bc63b14cc3d6f6ffde2100
28
https://www.miit.gov.cn/zwgk/zcwj/wjfb/tg/art/2022/art_281d5b2df5f249e3a1ac88db9fcf43c3.html
29
https://gdca.miit.gov.cn/xwdt/gzdt/art/2022/art_40d6b634664248d0b982470b98ab273e.html
30
http://www.21jingji.com/article/20220801/herald/3460406360e98054a415453eb50db210.html
31
https://mp.weixin.qq.com/s/w06mB72p9V_asia3Vijt5A?scene=25#wechat_redirect,
https://mp.weixin.qq.com/s/82rYeUUmNzCgehKjY4ifhA
32
https://news.sina.cn/gn/2022-08-17/detail-imizmscv6538401.d.html
33
https://www.chinacourt.org/article/detail/2022/08/id/6852195.shtml
34
http://rmfyb.chinacourt.org/paper/html/2022-08/11/content_219842.htm?div=-1
35
https://www.spp.gov.cn/spp/xwfbh/wsfbt/202208/t20220810_570413.shtml#1
36 https://mp.weixin.qq.com/s/YLY0acSs2n3DPD3lCWleGw
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