Cisco Systems, Inc. v. Doe · ¶63

To target Falun Gong members, the CCP determined that it needed to develop a sophisticated, nationwide internetsurveillance tool to track Falun Gong activity online. It thus devised the anti-Falun Gong “‘Golden Shield’”: a “‘vast and multi-tiered’” bespoke “‘surveillance system’” that the CCP contemplated would obtain and organize all manner of data on the Falun Gong members across China, including address information, internet history, and financial and family information. Id., at 710. At the time the CCP came up with the idea, however, Chinese engineers lacked the technical expertise to create such technology. As a result, the CCP turned to American technology companies and invited them to submit proposals to design its Golden Shield system.

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