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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On September 25, 2025, President Donald Trump issued an <a href="https://www.whitehouse.gov/presidential-actions/2025/09/saving-tiktok-while-protecting-national-security/" target="_blank" rel="noreferrer noopener">Executive Order</a> (EO), &ldquo;Saving TikTok While Protecting National Security&rdquo;, stating that &ldquo;a plan has been presented to me to undergo a qualified divestiture of TikTok&rsquo;s United States operations, as outlined in a framework agreement.&rdquo;&nbsp;While the agreement has not been made public, the EO indicates that:
<ul class="wp-block-list">
<li>TikTok&rsquo;s U.S. application will be operated by a newly established joint venture based in the United States;</li>
<li>TikTok will be majority-owned and controlled by U.S. persons and will no longer be controlled by any foreign adversary, since ByteDance Ltd. and its affiliates will own less than 20% of the entity, with the remainder held by certain investors;</li>
<li>the joint venture will be run by a new board of directors and subject to rules that appropriately protect Americans&rsquo; data and U.S. national security;</li>
<li>the divestiture puts the operation of the algorithms and code, as well as content-moderation decisions, under the control of the joint venture;</li>
<li>the divestiture prohibits the storage of sensitive U.S. user data in a manner that would place such data under the control of a foreign adversary and requires such data to be stored in a cloud environment run by a U.S. company; and</li>
<li>the divestiture includes intense monitoring of software updates, algorithms, and data flows by trusted security partners of the United States and requires all recommendation models, including algorithms, that use U.S. user data to be retrained and monitored by those trusted security partners.</li>
</ul>
While acknowledging that the Framework Agreement&rsquo;s implementation has not yet been completed, President Trump stated, &ldquo;I have determined that the proposed divestiture would allow the millions of Americans who enjoy TikTok every day to continue using it while also protecting national security.&rdquo; In order to permit the &ldquo;contemplated divestiture&rdquo; to be completed, the EO also directs that the U.S. Attorney General shall not take any action on behalf of the United States to enforce the Protecting Americans from Foreign Adversary Controlled Applications Act for 120 days.
China&rsquo;s divestiture of TikTok was required by law pursuant to the Protecting Americans from Foreign Adversary Controlled Applications Act enacted on April 24, 2024, as part of an emergency supplemental appropriations (<a href="https://filehost.thompsonhine.com/uploads/hr815_dd5f.pdf" target="_blank" rel="noreferrer noopener">Pub. Law No. 118-50</a>). The law passed after prior attempts to address any potential national security concerns with TikTok failed.&nbsp;For more details on these past actions, see Thompson Hine Updates of&nbsp;<a href="https://www.thompsonhinesmartrade.com/2024/04/president-biden-signs-law-that-includes-provisions-to-ban-tiktok-from-the-united-states/">April 30, 2024</a>, <a href="https://www.thompsonhinesmartrade.com/2020/08/president-trump-issues-executive-orders-prohibiting-transactions-related-to-tiktok-and-wechat/">August 7, 2020</a>,&nbsp;<a href="https://www.thompsonhinesmartrade.com/2020/08/president-trump-orders-chinese-company-bytedance-to-divest-its-holdings-in-tiktok-formerly-musical-ly/">August 17, 2020</a>,&nbsp;<a href="https://www.thompsonhinesmartrade.com/2020/10/federal-court-partially-blocks-department-of-commerce-tiktok-ban/">October 5, 2020</a>&nbsp;and&nbsp;<a href="https://www.thompsonhinesmartrade.com/2021/08/tiktok-and-wechat-national-security-cases-are-dismissed/">August 12, 2021</a>.

President Trump Signs Executive Order on China’s Divestment of TikTok

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