长江存储状告美国商务部及BIS：要求其公开制裁真相

Core Viewpoint - Yangtze Memory Technologies Co., Ltd. (YMTC) has filed a lawsuit against the U.S. Department of Commerce and its Bureau of Industry and Security (BIS) to demand the disclosure of the complete administrative record and internal decision-making process regarding its inclusion in the export control entity list in 2022 [1][5]. Group 1: Legal Action and Claims - The lawsuit is based on the Freedom of Information Act (FOIA) and does not directly challenge the export control measures themselves [1]. - YMTC argues that the announcement regarding its inclusion in the entity list contains significant anomalies compared to other companies, lacking clarity on the decision-making body and failing to provide specific factual bases for the inclusion [2][4]. - The company has submitted multiple compliance remedies and formally requested removal from the entity list, asserting that it has not violated any export control regulations [4][5]. Group 2: Request for Information - YMTC's FOIA request seeks three categories of critical information: communications between the U.S. Department of Commerce or BIS and third parties, the decision-making entities involved in the 2022 inclusion, and the complete administrative record including proposal documents and internal memos [5][6]. - The BIS did not respond within the statutory 20 working days, leading to a "constructive denial" under FOIA, allowing YMTC to proceed with the lawsuit [6]. Group 3: Implications and Significance - The lawsuit represents a strategic move by YMTC to challenge the lack of specific evidence supporting its inclusion in the entity list, highlighting the absence of any allegations of wrongdoing against the company [7]. - This action reflects the proactive stance of Chinese companies within the international regulatory framework and may serve as a reference for other firms facing opaque restrictions [7].