Attorney General William P. Barr Delivers Remarks on China Policy at the Gerald R. Ford Presidential Museum
Thursday, July 16, 2020
It is a privilege to be here to speak about what may prove to be the most important issue for our nation and the world in the twenty-first century — that is, the United States’ response to the global ambitions of the Chinese Communist Party. The CCP rules with an iron fist over one of the great ancient civilizations of the world. It seeks to leverage the immense power, productivity, and ingenuity of the Chinese people to overthrow the rules-based international system and to make the world safe for dictatorship. How the United States responds to this challenge will have historic implications and will determine whether the United States and its liberal democratic allies will continue to shape their own destiny or whether the CCP and its autocratic tributaries will control the future.
Several weeks ago, National Security Advisor Robert O’Brien spoke about the CCP’s ideology and global ambitions. He declared, and I agree, that “[t]he days of American passivity and naivety regarding the People’s Republic of China are over.” Last week, FBI Director Chris Wray described how the CCP pursues its ambitions through nefarious and even illegal conduct, including industrial espionage, theft, extortion, cyberattacks, and malign influence activities. In the coming days, you will hear from Secretary of State Mike Pompeo, who will sum up what is at stake for the United States and the free world. I hope these speeches will inspire the American people to reevaluate their relationship with China, so long as it continues to be ruled by the Communist Party.
It is fitting that we are here today at the Ford Presidential Museum. Gerald Ford served at the highest echelons of our government at the dawn of America’s reengagement with the People’s Republic of China, which began with President Nixon’s historic visit in 1972. Three years later, in 1975, President Ford visited China for a summit with PRC leaders, including Mao Zedong.
At the time, it was unthinkable that China would emerge after the Cold War as a near-peer competitor of the United States. Yet even then, there were signs of China’s immense latent power. In the joint report of their visit to China in 1972, House Majority Leader Hale Boggs and then-Minority Leader Ford wrote: “If she manages to achieve as she aspires, China in the next half century can emerge a self-sufficient power of a billion people …. This last impression—of the reality of China’s colossal potential—is perhaps the most vivid of our journey. As our small party traveled through that boundless land, this sense of a giant stirring, a dragon waking, gave us much to ponder.” It is now nearly fifty years later, and the prescient ponderings of these two congressmen have come to pass.
Deng Xiaoping, whose economic reforms launched China’s remarkable rise, had a famous motto: “hide your strength and bide your time.” That is precisely what China has done. China’s economy has quietly grown from about 2 percent of the world’s GDP in 1980 to nearly 20 percent today. By some estimates, based on purchasing power parity, the Chinese economy is already larger than ours. The General Secretary of the Chinese Communist Party, Xi Jinping, who has centralized power to a degree not seen since the dictatorship of Mao Zedong, now speaks openly of China moving “closer to center stage,” “building a socialism that is superior to capitalism,” and replacing the American Dream with the “Chinese solution.” China is no longer hiding its strength, nor biding its time. From the perspective of its communist rulers, China’s time has arrived.
The People’s Republic of China is now engaged in an economic blitzkrieg—an aggressive, orchestrated, whole-of-government (indeed, whole-of-society) campaign to seize the commanding heights of the global economy and to surpass the United States as the world’s preeminent superpower. A centerpiece of this effort is the Communist Party’s “Made in China 2025” initiative, a plan for PRC domination of high-tech industries like robotics, advanced information technology, aviation, and electric vehicles. Backed by hundreds of billions of dollars in subsidies, this initiative poses a real threat to U.S. technological leadership. Despite World Trade Organization rules prohibiting quotas for domestic output, “Made in China 2025” sets targets for domestic market share (sometimes as high as 70 percent) in core components and basic materials for industries such as robotics and telecommunications. It is clear that the PRC seeks not merely to join the ranks of other advanced industrial economies, but to replace them altogether.
“Made in China 2025” is the latest iteration of the PRC’s state-led, mercantilist economic model. For American companies in the global marketplace, free and fair competition with China has long been a fantasy. To tilt the playing field to its advantage, China’s communist government has perfected a wide array of predatory and often unlawful tactics: currency manipulation, tariffs, quotas, state-led strategic investment and acquisitions, theft and forced transfer of intellectual property, state subsidies, dumping, cyberattacks, and espionage. About 80% of all federal economic espionage prosecutions have alleged conduct that would benefit the Chinese state, and about 60% of all trade secret theft cases have had a nexus to China.
The PRC also seeks to dominate key trade routes and infrastructure in Eurasia, Africa, and the Pacific. In the South China Sea, for example, through which about one-third of the world’s maritime trade passes, the PRC has asserted expansive and historically dubious claims to nearly the entire waterway, flouted the rulings of international courts, built artificial islands and placed military outposts on them, and harassed its neighbors’ ships and fishing boats.
Another ambitious project to spread its power and influence is the PRC’s “Belt and Road” infrastructure initiative. Although billed as “foreign aid,” in fact these investments appear designed to serve the PRC’s strategic interests and domestic economic needs. For example, the PRC has been criticized for loading poor countries up with debt, refusing to renegotiate terms, and then taking control of the infrastructure itself, as it did with the Sri Lankan port of Hambantota in 2017. This is little more than a form of modern-day colonialism.
Just as consequential, however, are the PRC’s plans to dominate the world’s digital infrastructure through its “Digital Silk Road” initiative. I have previously spoken at length about the grave risks of allowing the world’s most powerful dictatorship to build the next generation of global telecommunications networks, known as 5G. Perhaps less widely known are the PRC’s efforts to surpass the United States in other cutting-edge fields like artificial intelligence. Through innovations such as machine learning and big data, artificial intelligence allows machines to mimic human functions, such as recognizing faces, interpreting spoken words, driving vehicles, and playing games of skill such as chess or the even more complex Chinese strategy game Go. AI long ago outmatched the world’s chess grandmasters. But the PRC’s interest in AI accelerated in 2016, when AlphaGo, a program developed by a subsidiary of Google, beat the world champion Go player at a match in South Korea. The following year, Beijing unveiled its “Next Generation Artificial Intelligence Plan,” a blueprint for leading the world in AI by 2030. Whichever nation emerges as the global leader in AI will be best positioned to unlock not only its considerable economic potential, but a range of military applications, such as the use of computer vision to gather intelligence.
The PRC’s drive for technological supremacy is complemented by its plan to monopolize rare earth materials, which play a vital role in industries such as consumer electronics, electric vehicles, medical devices, and military hardware. According to the Congressional Research Service, from the 1960s to the 1980s, the United States led the world in rare earth production. “Since then, production has shifted almost entirely to China,” in large part due to lower labor costs and lighter environmental regulation.
The United States is now dangerously dependent on the PRC for these materials. Overall, China is America’s top supplier, accounting for about 80 percent of our imports. The risks of dependence are real. In 2010, for example, Beijing cut exports of rare earth materials to Japan after an incident involving disputed islands in the East China Sea. The PRC could do the same to us.
As China’s progress in these critical sectors illustrates, the PRC’s predatory economic policies are succeeding. For a hundred years, America was the world’s largest manufacturer — allowing us to serve as the world’s “arsenal of democracy.” China overtook the United States in manufacturing output in 2010. The PRC is now the world’s “arsenal of dictatorship.”
How did China accomplish all this? No one should underestimate the ingenuity and industry of the Chinese people. At the same time, no one should doubt that America made China’s meteoric rise possible. China has reaped enormous benefits from the free flow of American aid and trade. In 1980, Congress granted the PRC most-favored-nation trading status. In the 1990s, American companies strongly supported the PRC’s accession to the World Trade Organization and the permanent normalization of trade relations. Today, U.S.-China trade totals about $700 billion.
Last year, Newsweek ran a cover story titled “How America’s Biggest Companies Made China Great Again.” The article details how China’s communist leaders lured American business with the promise of market access, and then, having profited from American investment and know-how, turned increasingly hostile. The PRC used tariffs and quotas to pressure American companies to give up their technology and form joint ventures with Chinese companies. Regulators then discriminated against American firms, using tactics like holding up permits. Yet few companies, even Fortune 500 giants, have been willing to bring a formal trade complaint for fear of angering Beijing.
Just as American companies have become dependent on the Chinese market, the United States as a whole now relies on the PRC for many vital goods and services. The COVID-19 pandemic has thrown a spotlight on that dependency. For example, China is the world’s largest producer of certain protective equipment, such as face masks and medical gowns. In March, as the pandemic spread around the world, the PRC hoarded the masks for itself, blocking producers — including American companies — from exporting them to countries in need. It then attempted to exploit the shortage for propaganda purposes, shipping limited quantities of often defective equipment and requiring foreign leaders to publicly thank Beijing.
China’s dominance of the world market for medical goods goes beyond masks and gowns. It has become the United States’ largest supplier of medical devices, while at the same time discriminating against American medical companies in China. China’s government has targeted foreign firms for greater regulatory scrutiny, instructed Chinese hospitals to buy products made in China, and pressured American firms to build factories in China, where their intellectual property is more vulnerable to theft. As one expert has observed, American medical device manufacturers are effectively “creating their own competitors.”
America also depends on Chinese supply chains in other vital sectors, especially pharmaceuticals. America remains the global leader in drug discovery, but China is now the world’s largest producer of active pharmaceutical ingredients, known as “APIs.” As one Defense Health Agency official noted, “[s]hould China decide to limit or restrict the delivery of APIs to the [United States],” it “could result in severe shortages of pharmaceuticals for both domestic and military uses.”
To achieve dominance in pharmaceuticals, China’s rulers went to the same playbook they used to gut other American industries. In 2008, the PRC designated pharmaceutical production as a “high-value-added-industry” and boosted Chinese companies with subsidies and export tax rebates. Meanwhile, the PRC has systematically preyed on American companies. American firms face well-known obstacles in China’s health market, including drug approval delays, unfair pricing limitations, IP theft, and counterfeiting. Chinese nationals working as employees at pharma companies have been caught stealing trade secrets both in America and in China. And the CCP has long engaged in cyber-espionage and hacking of U.S. academic medical centers and healthcare companies.
In fact, PRC-linked hackers have targeted American universities and firms in a bid to steal IP related to coronavirus treatments and vaccines, sometimes disrupting the work of our researchers. Having been caught covering up the coronavirus outbreak, Beijing is desperate for a public relations coup, and may hope that it will be able to claim credit for any medical breakthroughs.
As all of these examples should make clear, the ultimate ambition of China’s rulers isn’t to trade with the United States. It is to raid the United States. If you are an American business leader, appeasing the PRC may bring short-term rewards. But in the end, the PRC’s goal is to replace you. As a U.S. Chamber of Commerce report put it, “[t]he belief by foreign companies that large financial investments, the sharing of expertise and significant technology transfers would lead to an ever opening China market is being replaced by boardroom banter that win-win in China means China wins twice.”
Although Americans hoped that trade and investment would liberalize China’s political system, the fundamental character of the regime has never changed. As its ruthless crackdown of Hong Kong demonstrates once again, China is no closer to democracy today than it was in 1989 when tanks confronted pro-democracy protesters in Tiananmen Square. It remains an authoritarian, one-party state in which the Communist Party wields absolute power, unchecked by popular elections, the rule of law, or an independent judiciary. The CCP surveils its own people and assigns them social credit scores, employs an army of government censors, tortures dissidents, and persecutes religious and ethnic minorities, including a million Uighurs detained in indoctrination and labor camps.
If what happened in China stayed in China, that would all be bad enough. But instead of America changing China, China is leveraging its economic power to change America. As this Administration’s China Strategy recognizes, “the CCP’s campaign to compel ideological conformity does not stop at China’s borders.” Rather, the CCP seeks to extend its influence around the world, including on American soil.
All too often, for the sake of short-term profits, American companies have succumbed to that influence—even at the expense of freedom and openness in the United States. Sadly, examples of American business bowing to Beijing are legion.
Take Hollywood. Hollywood actors, producers, and directors pride themselves on celebrating freedom and the human spirit. And every year at the Academy Awards, Americans are lectured about how this country falls short of Hollywood’s ideals of social justice. But Hollywood now regularly censors its own movies to appease the Chinese Communist Party, the world’s most powerful violator of human rights. This censorship infects not only versions of movies that are released in China, but also many that are shown in American theaters to American audiences.
For example, the hit movie World War Z depicts a zombie apocalypse caused by a virus. The original version of the film reportedly contained a scene with characters speculating that the virus may have originated in China. (In the novel, Patient Zero is a boy from Chongqing.) But the studio, Paramount Pictures, reportedly told producers to delete the reference to China in the hope of landing a Chinese distribution deal. The deal never materialized.
In the Marvel Studios blockbuster Dr. Strange, filmmakers changed the nationality of a major character known as the “Ancient One,” a Tibetan monk in the comic books, from Tibetan to Celtic. When challenged about this, a screenwriter explained that “if you acknowledge that Tibet is a place and that he’s Tibetan, you risk alienating one billion people.” Or, he continued, the Chinese government might say “[w]e’re not going to show your movie because you decided to get political.”
These are just two examples of the many Hollywood films that have been altered, one way or another, to conform to CCP propaganda. National Security Advisor O’Brien offered even more examples in his remarks. But many more scripts likely never see the light of day, because writers and producers know not to even test the limits. Chinese government censors don’t need to say a word, because Hollywood is doing their work for them. This is a massive propaganda coup for the Chinese Communist Party.
The story of the film industry’s submission to the CCP is a familiar one. In the past two decades, China has emerged as the world’s largest box office. The CCP has long tightly controlled access to that lucrative market—both through quotas on American films, imposed in violation of China’s WTO obligations, and a strict censorship regime. Increasingly, Hollywood also relies on Chinese money for financing. In 2018, films with Chinese investors accounted for 20 percent of U.S. box-office ticket sales, compared to only 3.8 percent five years earlier.
But in the long run, as with other American industries, the PRC may be less interested in cooperating with Hollywood than co-opting Hollywood—and eventually replacing it with its own homegrown productions. To accomplish this, the CCP has been following its usual modus operandi. By imposing a quota on American films, the CCP pressures Hollywood studios to form joint ventures with Chinese companies, who then gain access to U.S. technology and know-how. As one Chinese film executive recently put it, “[e]verything we learned, we learned from Hollywood.” Notably, in 2019, eight of the 10 top-grossing films in China were produced in China.
Hollywood is far from alone in kowtowing to the PRC. America’s big tech companies have also allowed themselves to become pawns of Chinese influence.
In the year 2000, when the United States normalized trade relations with China, President Clinton hailed the new century as one in which “liberty will be spread by cell phone and cable modem.” Instead, over the course of the next decade, American companies such as Cisco helped the Communist Party build the Great Firewall of China—the world’s most sophisticated system for Internet surveillance and censorship.
Over the years, corporations such as Google, Microsoft, Yahoo, and Apple have shown themselves all too willing to collaborate with the CCP. For example, Apple recently removed the news app Quartz from its app store in China, after the Chinese government complained about coverage of the Hong Kong democracy protests. Apple also removed apps for virtual private networks, which had allowed users to circumvent the Great Firewall, and eliminated pro-democracy songs from its Chinese music store. Meanwhile, the company announced that it would be transferring some of its iCloud data to servers in China, despite concerns that the move would give the CCP easier access to e-mails, text messages, and other user information stored in the cloud.
The CCP has long used public threats of retaliation and barred market access to exert influence. More recently, however, the CCP has also stepped up behind-the-scenes efforts to cultivate and coerce American business executives to further its political objectives — efforts that are all the more pernicious because they are largely hidden from public view.
As China’s government loses credibility around the world, the Department of Justice has seen more and more PRC officials and their proxies reaching out to corporate leaders and inveighing them to favor policies and actions favored by the Chinese Communist Party. Their objective varies, but their pitch is generally the same: the businessperson has economic interests in China, and there is a suggestion that things will go better (or worse) for them depending on their response to the PRC’s request. Privately pressuring or courting American corporate leaders to promote policies (or politicians) presents a significant threat, because hiding behind American voices allows the Chinese government to elevate its influence and put a “friendly face” on pro-regime policies. The legislator or policymaker who hears from a fellow American is properly more sympathetic to that constituent than to a foreigner. And by masking its participation in our political process, the PRC avoids accountability for its influence efforts and the public outcry that might result, if its lobbying were exposed.
America’s corporate leaders might not think of themselves as lobbyists. You might think, for example, that cultivating a mutually beneficial relationship is just part of the “guanxi” — or system of influential social networks—necessary to do business with the PRC. But you should be alert to how you might be used, and how your efforts on behalf of a foreign company or government could implicate the Foreign Agents Registration Act. FARA does not prohibit any speech or conduct. But it does require those who are acting as the “agents” of foreign principals to publicly disclose that relationship and their political or other similar activities by registering with the Justice Department, allowing the audience to take into account the origin of the speech when evaluating its credibility.
These requirements are designed not to stifle your rights to free expression, which are protected by the First Amendment, but rather to ensure that the American public and their legislators can discern what or who is the true source of speech on matters of public concern.
By focusing on American business leaders, of course, I don’t mean to suggest that they are the only targets of Chinese influence operations. The Chinese Communist Party also seeks to infiltrate, censor, or co-opt American academic and research institutions. For example, dozens of American universities host Chinese government-funded “Confucius Institutes,” which have been accused of pressuring host universities to silence discussion or cancel events on topics considered controversial by Beijing. Universities must stand up for each other; refuse to let the CCP dictate research efforts or suppress diverse voices; support colleagues and students who wish to speak their minds; and consider whether any sacrifice of academic integrity or freedom is worth the price of appeasing the CCP’s demands.
In a globalized world, American corporations and universities alike may view themselves as global citizens, rather than American institutions. But they should remember that what allowed them to succeed in the first place was the American free enterprise system, the rule of law, and the security afforded by America’s economic, technological, and military strength.
Globalization does not always point in the direction of greater freedom. A world marching to the beat of Communist China’s drums will not be a hospitable one for institutions that depend on free markets, free trade, or the free exchange of ideas.
There was a time American companies understood that. They saw themselves as American and proudly defended American values.
In World War II, for example, the iconic American company, Disney, made dozens of public information films for the government, including training videos to educate American sailors on navigation tactics. During the war, over 90 percent of Disney employees were devoted to the production of training and public information films. To boost the morale of America’s troops, Disney also designed insignia that appeared on planes, trucks, flight jackets, and other military equipment used by American and Allied forces.
I suspect Walt Disney would be disheartened to see how the company he founded deals with the foreign dictatorships of our day. When Disney produced Kundun, the 1997 film about the PRC’s oppression of the Dalai Lama, the CCP objected to the project and pressured Disney to abandon it. Ultimately, Disney decided that it couldn’t let a foreign power dictate whether it would distribute a movie in the United States.
But that moment of courage wouldn’t last long. After the CCP banned all Disney films in China, the company lobbied hard to regain access. The CEO apologized for Kundun, calling it a “stupid mistake.” Disney then began courting the PRC to open a $5.5 billion theme park in Shanghai. As part of that deal, Disney agreed to give Chinese government officials a role in management. Of the park’s 11,000 full-time employees, 300 are active members of the Communist Party. They reportedly display hammer-and-sickle insignia at their desks and attend Party lectures during business hours.
Like other American companies, Disney may eventually learn the hard way the cost of compromising its principles. Soon after Disney opened its park in Shanghai, a Chinese-owned theme park popped up a couple hundred miles away featuring characters that, according to news reports, looked suspiciously like Snow White and other Disney trademarks.
American companies must understand the stakes. The Chinese Communist Party thinks in terms of decades and centuries, while we tend to focus on the next quarterly earnings report. But if Disney and other American corporations continue to bow to Beijing, they risk undermining both their own future competitiveness and prosperity, as well as the classical liberal order that has allowed them to thrive.
During the Cold War, Lewis Powell — later Justice Powell — sent an important memorandum to the U.S. Chamber of Commerce. He noted that the free enterprise system was under unprecedented attack, and urged American companies to do more to preserve it. “[T]he time has come,” he said, “indeed, it is long overdue—for the wisdom, ingenuity and resources of American business to be marshaled against those who would destroy it.”
So too today. The American people are more attuned than ever to the threat that the Chinese Communist Party poses not only to our way of life, but to our very lives and livelihoods. And they will increasingly call out corporate appeasement.
If individual companies are afraid to make a stand, there is strength in numbers. As Justice Powell wrote: “Strength lies in organization, in careful long-range planning and implementation, in consistency of action over an indefinite period of years, in the scale of financing available only through joint effort, and in the political power available only through united action and national organizations.” Despite years of acquiescence to communist authorities in China, American tech companies may finally be finding their courage through collective action. Following the recent imposition of the PRC’s draconian national security law in Hong Kong, many big tech companies, including Facebook, Google, Twitter, Zoom, and LinkedIn, reportedly announced that they would temporarily suspend compliance with governmental requests for user data. True to form, communist officials have threatened imprisonment for noncompliant company employees. We will see if these companies hold firm. I hope they do. If they stand together, they will provide a worthy example for other American companies in resisting the Chinese Communist Party’s corrupt and dictatorial rule.
The CCP has launched an orchestrated campaign, across all of its many tentacles in Chinese government and society, to exploit the openness of our institutions in order to destroy them. To secure a world of freedom and prosperity for our children and grandchildren, the free world will need its own version of the whole-of-society approach, in which the public and private sectors maintain their essential separation but work together collaboratively to resist domination and to win the contest for the commanding heights of the global economy. America has done that before. If we rekindle our love and devotion for our country and each other, I am confident that we—the American people, American government, and American business together—can do it again. Our freedom depends on it.
 Robert C. O’Brien, National Security Advisor, “The Chinese Communist Party’s Ideology and Global Ambitions,” June 24, 2020, https://www.whitehouse.gov/briefings-statements/chinese-communist-partys-ideology-global-ambitions.
 Christopher A. Wray, Director of the Federal Bureau of Investigation, “The Threat Posed by the Chinese Government and the Chinese Communist Party to the Economic and National Security of the United States,” July 7, 2020, https://www.fbi.gov/news/speeches/the-threat-posed-by-the-chinese-government-and-the-chinese-communist-party-to-the-economic-and-national-security-of-the-united-states.
 Hale Boggs & Gerald R. Ford, “Impressions of the New China,” H.R. Doc. No. 92-337, at 3 (1972), https://www.fordlibrarymuseum.gov/library/document/0358/035800376.pdf.
 Evan Osnos, “Making China Great Again,” January 1, 2018, https://www.newyorker.com/magazine/2018/01/08/making-china-great-again.
 Id.; Department of Justice, “Attorney General William P. Barr Delivers the Keynote Address at the Department of Justice’s China Initiative Conference,” February 6, 2020, https://www.justice.gov/opa/speech/attorney-general-william-p-barr-delivers-keynote-address-department-justices-china.
 Bill Powell, “How America’s Biggest Companies Made China Great Again,” June 24, 2019, https://www.newsweek.com/how-americas-biggest-companies-made-china-great-again-1445325.
 Rosemary Gibson et al., “China Rx: Exposing the Risks of America’s Dependence on China for Medicine,” at 124 (2018).
 Hearing Exploring the Growing U.S. Reliance on China’s Biotech and Pharmaceutical Products Before the U.S.-China Economic and Security Review Comm., 116 Cong., at 25 (2019) (written testimony of Christopher Priest, Principal Deputy, Deputy Assistant Director, Healthcare Operations Defense Health Agency), https://www.uscc.gov/sites/default/files/2019-10/July%2031,%202019%20Hearing%20Transcript.pdf.
 U.S.-China Economic and Security Review Comm., “2019 Report to Congress,” 116 Cong., at 253 (2019), https://www.uscc.gov/sites/default/files/2019-11/2019%20Annual%20Report%20to%20Congress.pdf.
 James McGregor, “China’s Drive for ‘Indigenous Innovation’—A Web of Industrial Policies,” at 6 (2010), https://www.uschamber.com/sites/default/files/documents/files/100728chinareport_0_0.pdf.
 White House, “United States Strategic Approach to the People’s Republic of China,” at 5 (2020), https://www.whitehouse.gov/wp-content/uploads/2020/05/U.S.-Strategic-Approach-to-The-Peoples-Republic-of-China-Report-5.24v1.pdf.
 Edward Wong, “‘Doctor Strange’ Writer Explains Casting of Tilda Swinton as Tibetan,” April 26, 2016, https://www.nytimes.com/2016/04/27/world/asia/china-doctor-strange-tibet.html.
 Sean O’Connor & Nicholas Armstrong, Esq., “Directed by Hollywood, Edited by China: How China’s Censorship and Influence Affect Films Worldwide,” at 6 (2015), https://www.uscc.gov/sites/default/files/Research/Directed%20by%20Hollywood%20Edited%20by%20China.pdf.
 James Griffiths, “The Great Firewall of China: How to Build and Control an Alternative Version of the Internet,” at 42 (2019).
 Department of Justice, “The Scope of Agency Under FARA,” May 2020, https://www.justice.gov/nsd-fara/page/file/1279836/download.
 David Barboza & Brooks Barnes, “How China Won the Keys to Disney’s Magic Kingdom,” June 14, 2016, https://www.nytimes.com/2016/06/15/business/international/china-disney.html.
 Lewis F. Powell, Jr., “Attack on American Free Enterprise System,” at 9 (August 23, 1971), https://www.reuters.com/investigates/special-report/assets/usa-courts-secrecy-lobbyist/powell-memo.pdf.
 Id. at 11.