Legal Conflicts in China-US Cross-border Data Governance - A Case Study of Data Localization Policies and the Game of Extra-territorial Jurisdiction

With the deepening of the globalization of digital trade, cross-border flow of data has now become one of the core issues in international trade, and the legal conflicts between China and the United States in the field of data governance have become more and more prominent. The Chinese side advocates strengthening data localization requirements with the Data Security Law and the Personal Information Protection Law, upholding the principle of "security first",while the US side relies on the Cloud Act to expand its extraterritorial jurisdiction and advocate the "free flow of data", which creates a double constraint in the rules. This constitutes a certain sense of double constraint within the rules. This conflict is essentially a game of national sovereignty and jurisdiction in the digital age. This game not only plunged multinational enterprises into a double predicament, but also exposed the limitations of traditional international law in the digital domain. In order to solve the problems shown above, this study adopts more than two solution methods, such as the literature research method, the comparative research method, and the case study method, to systematically sort out the manifestations and causes of the legal conflicts of data governance between China and the United States, to analyze the inadequacies of existing studies in various aspects, and finally to propose different reconciliation paths from various aspects.This research aims to provide relevant references for multinational enterprises, thereby promoting the reconstruction of the international law framework and effectively offering theoretical support for the reform of the global data governance system.