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June 3, 20260 citationsOpen Access

Incompatible Sovereignties: Chokepoint Conflict and the Structure of Digital Governance

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XFXiaotong Fu

Key Points

  • This research investigates the interactions between different digital governance authorities and how they lead to conflicts.
  • Analyzed three conflict scenarios involving U.S. platform governance, EU regulatory governance, and Chinese infrastructure sovereignty.
  • Examined empirical cases including data transfer conflicts and TikTok divestiture to illustrate governance chokepoints.
  • Utilized legislative texts, judicial rulings, and policy documents for in-depth analysis.
  • Identified compliance-priority conflicts arising from intersecting governance logics in digital platforms and infrastructure.
  • Demonstrated that standard-export and law-spillover mechanisms explain the incompatibility of governance between major powers.
  • Proposed that flow dependence without rule convertibility leads to alternative investment strategies, not compliance conflicts.

Abstract

This thesis examines what happens when different types of structural digital power intersect in the same dependent actor. Drawing on Strange's concept of structural power and extending Farrell and Newman's framework of weaponized interdependence, it argues that three forms of structural digital capability: platform ecosystem control (the United States), infrastructure sovereignty control (China), and market-regulatory access control (the European Union) function as governance chokepoints whose constitutive governance logics cannot be simultaneously satisfied. Each chokepoint type converts flow dependence into sustained, cross-border rule acceptance through a distinct pathway: legal jurisdiction over platform ecosystems, legal obligations embedded in deployed infrastructure, and market conditionality operating through the Brussels Effect. When these logics intersect in the same firm, state, or user, they produce compliance-priority conflicts whose recurrence is constitutive rather than incidental. The argument is developed through a conflict-scenario comparison across three empirical cases and one contrasting case, drawing on legislative texts, judicial rulings, regulatory decisions, and official policy documents. The first scenario traces the structural incompatibility between U.S. platform governance and EU regulatory governance through the transatlantic data transfer conflict from Schrems II (2020) to the EU–U.S. Data Privacy Framework (2023). The second scenario examines the collision between U.S. platform governance and Chinese infrastructure sovereignty governance through the TikTok divestiture episode (2020–2025), demonstrating that even the most elaborate technical mitigation (Project Texas) could not resolve a political-layer incompatibility between FISA Section 702 and China's National Intelligence Law. The third scenario analyzes the confrontation between Chinese infrastructure sovereignty and a U.S.-led coalition through the cascading 5G exclusion decisions (2018–2021), revealing a previously undertheorized law-spillover mechanism through which governance obligations travel with deployed equipment rather than through explicit legal demands. South Korea's semiconductor supply chain centrality is examined as a contrasting case to establish the boundary condition of the framework: substantial flow dependence that lacks rule convertibility produces diversification investment rather than compliance-priority conflict. The thesis makes three theoretical contributions. First, it extends the chokepoint concept from episodic coercive leverage to sustained governance authority that operates continuously through the ordinary functioning of network positions. Second, it distinguishes two subtypes of infrastructure sovereignty chokepoint—standards-export and law-spillover—resolving an ambiguity in the existing literature on Chinese digital power projection. Third, it identifies compliance-priority conflict as a structurally predictable consequence of intersecting governance logics rather than a contingent byproduct of overlapping regulatory ambitions. The analysis reveals the global digital order as a field of structural conflict among three governance logics whose authority is simultaneously real, self-reinforcing, and mutually incompatible at the political layer.

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Cite This Study

Xiaotong Fu (2026) studied this question.

synapsesocial.com/papers/6a1fc44edee9eb8c0dce5e37https://doi.org/10.6082/gnz70-gx506
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