Transnational Judicial Dilemmas and Rule Reconstruction in Digital Legacy Inheritance: An Empirical Analysis Based on Differences in User Agreements of Chinese and American Social Platforms

As digital existence becomes a fundamental form of modern society, digital legacy inheritance has evolved into a significant legal issue transcending national borders and legal jurisdictions. This paper focuses on the rule conflicts and judicial practice dilemmas in digital legacy inheritance between Chinese and American social platforms. Through an empirical analysis of user agreements (2019-2025) from 12 mainstream platforms including Facebook, Twitter, WeChat, and Weibo, combined with 34 typical cases from China and the US, it reveals fundamental conflicts in the legal attribute determination, boundaries of platform liability, and privacy protection standards for transnational digital legacy inheritance. Research findings show: US platforms predominantly adopt a "digital will" model, allowing users to designate legacy contacts during their lifetime (87.5% of platforms support this), while Chinese platforms emphasize an "account freezing" mechanism (only 33.3% support inheritance). Regarding data portability, conflicts exist between the extension of rights under the EU GDPR framework[1]and China's "Measures on the Standard Contract for the Outbound Transfer of Personal Information". A transnational digital legacy notarization chain based on blockchain technology could serve as an innovative pathway to resolve jurisdictional dilemmas. This study provides jurisprudential support for constructing a transnational digital legacy inheritance rule system centered on "autonomy of will prioritized, platform liability as a safety net".