Five entities, one pitch deck
The US State Department said on 19 October that it is sanctioning five China-based entities connected to Linwei Ding, the former Google software engineer convicted earlier this year of stealing the company’s confidential documents. The designations were made under the Protecting American Intellectual Property Act, a 2023 statute codified at 50 U.S.C. 1709.
The named entities are Shanghai Zhisuan Technology Co Ltd, the company Ding established in 2023; Qiji Chuangtan Beijing Investment Management Co Ltd, which operates as MiraclePlus; two venture capital funds it manages, Beijing Qiji Chuangtan Phase I Venture Capital Center Limited Partnership, established in 2020, and Phase II, established in 2022; and Beijing Qiji Chuangtan Zhiyuan Enterprise Management Center Limited Partnership, which the department says is wholly owned by Phase I.
What the department says the pitch contained
The State Department’s fact sheet is unusually specific about how the money moved. Zhisuan, it says, was marketed as capable of developing a software platform that could accelerate machine learning workloads, including training large super intelligence models on supercomputing chips.
Ding applied on Zhisuan’s behalf to MiraclePlus, a Chinese startup incubation programme that the department describes as a venture firm investing primarily in Chinese tech startups and running two startup camps a year. In that application, according to the fact sheet, Ding touted his experience with and knowledge of Google’s technology and internal systems, and claimed Zhisuan could replicate Google’s infrastructure technology. MiraclePlus gave seed capital in exchange for an ownership stake.
The legal findings
The department makes three distinct determinations. Zhisuan, it says, is a foreign person that knowingly engaged in, or benefitted from, significant theft of trade secrets of United States persons occurring on or after 5 January 2023. MiraclePlus is a foreign person that provided significant financial, material or technological support for that theft. Phase I, Phase II and Zhiyuan Enterprise are designated as entities owned or controlled by, or acting on behalf of, MiraclePlus.
The underlying conviction is the anchor. On 29 January 2026, a US federal jury convicted Ding on seven counts of theft of trade secrets, for taking what the department describes as thousands of pages of Google’s confidential information related to super intelligence technology, to benefit himself and China-based tech companies. The designations, the department says, follow an investigation by the Department of Justice and the FBI.
What the sanctions do
PAIPA mandates sanctions against certain foreign persons who have engaged in or benefited from significant theft of US trade secrets, and against persons associated with them. The department says five of the measures listed in the statute — sections 2(b)(1)(A), (D), (H), (I) and (J) — now apply to each of the five entities.
The statement closes on delisting rather than punishment: “The power and integrity of U.S. sanctions programs derive not only from the U.S. government’s ability to designate and add persons to sanctions lists but also from its willingness to remove persons from such lists consistent with the law,” it reads. “The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.”
What makes this designation worth watching is the target. Sanctioning a venture firm for backing a startup, on the basis of what the founder claimed in an application, draws a line much earlier in the chain than an export control does — at the point where capital meets a pitch.
