On July 11, 2025, the Trump Administration published an Order entitled "Regarding the Acquisition of Jupiter Systems, LLC by Suirui International Co., Limited" (dated July 8, 2025). This Order prohibits the February 2020 acquisition of Jupiter Systems, LLC ("Jupiter"), a Delaware company (subsequently converted into Jupiter Systems, Inc., a Delaware corporation) by Suirui International Co., Limited, a Hong Kong company that is majority-owned by Suirui Group Co., Ltd. ("Suirui"), a Chinese company.
Initial Transaction and Risks Identified
Jupiter is an audiovisual equipment supplier focused on large screen data and visualization experiences and Suirui focuses on video communication and video cloud service technology.
As described in a Department of Treasury press release, the Committee on Foreign Investment in the United States ("CFIUS") investigated the 2020 transaction pursuant to Section 721 of the Defense Production Act of 1950, determining that Suirui's ownership of Jupiter—including the potential compromise of "Jupiter's products used in military and critical infrastructure environments"—constitutes a national security risk.
President Donald Trump addressed this risk by ordering the divestment of all interests and rights in Jupiter held by Suirui and, further, requiring that Jupiter hold no interests or rights in any of its Chinese subsidiaries acquired or created post-transaction.
Divestment Requirements
Pursuant to the Order, the divestment shall occur within 120 days of the Order (subject to extension) and include all interests and rights in Jupiter (including, without limitation, tangible or intangible assets or property, wherever located, including its intellectual property, non-public source code associated with Jupiter products, and customer contracts, except those assets and operations of the Jupiter Asia Companies acquired or created after the 2020 transaction).
CFIUS is granted broad latitude to supervise the divestment, and its authority includes the review of and ability to object to intended purchasers, the ability to inspect and copy Suirui's and Jupiter's books and records, and the right to implement measures to further mitigate risk to the national security of the United States.
Further, pursuant to the Order, Suirui is directed to ensure that its personnel, affiliates, and affiliates' personnel refrain from accessing Jupiter's non-public source code, non-public technical information, information technology systems, products, parts and components, books and records, or facilities in the United States unless otherwise approved by CFIUS.
Takeaways
This Order aligns with the Trump Administration's "America First Investment Policy," and clearly signals the reinvigorated focus on Chinese foreign investment in American companies and the Administration's willingness to utilize CFIUS's sweeping review authority, including review of long-closed transactions. To avoid risks associated with future review (and potential divestment requirements), potential foreign investors are encouraged to carefully consider making pre-transaction filings to clarify CFIUS's view of the contemplated transaction.
Visit us at mayerbrown.com
Mayer Brown is a global services provider comprising associated legal practices that are separate entities, including Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown (a Hong Kong partnership) and Tauil & Chequer Advogados (a Brazilian law partnership) and non-legal service providers, which provide consultancy services (collectively, the "Mayer Brown Practices"). The Mayer Brown Practices are established in various jurisdictions and may be a legal person or a partnership. PK Wong & Nair LLC ("PKWN") is the constituent Singapore law practice of our licensed joint law venture in Singapore, Mayer Brown PK Wong & Nair Pte. Ltd. Details of the individual Mayer Brown Practices and PKWN can be found in the Legal Notices section of our website. "Mayer Brown" and the Mayer Brown logo are the trademarks of Mayer Brown.
© Copyright 2025. The Mayer Brown Practices. All rights reserved.
This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.
