Tech company responses and the UNGP ARTICLE 19 This review of tech company responses to digital authoritarianism in China, Vietnam, and Myanmar reveals some common threads. We highlight 5 key issues below. Deferring to local laws when explaining actions in violation of human rights First, tech companies more or less consistently defer to local law and rely on this justification when explaining their decisions to take actions which compromise human rights. Such deference to local law is consistent across the companies that have remained active in the focus countries and across countries. Although some companies made general references to the UNGPs or human rights, none provided detailed information about how they resolve conflicts between local law and human rights responsibilities. Instead, they appear to have accepted local legal regimes largely at face value. The UNGPs acknowledge that companies must abide by local law, but they also indicate that where domestic law and human rights principles conflict, businesses should respect human rights principles ‘to the greatest extent possible in the circumstances’, and that they should be able to demonstrate their efforts to do so. This means that they cannot merely defer to the need to follow local law. As highlighted already: the GNI provides concrete guidance on navigating such situations, including demanding specificity and clarity from governments, requiring governments to show the legal basis for requests, and interpreting government demands narrowly. It also encourages companies to take steps such as seeking modifications to such demands or challenging them in local courts. Unfortunately, the situations highlighted in this report do not provide much evidence that companies are respecting the UNGPs or the GNI principles in practice. For example, the UN Special Rapporteur on freedom of expression, in a letter to Apple, asked for clarification about its decision to remove VPN apps from its app store, which it had said it did to meet new regulations. The Special Rapporteur asked for more information about whether Chinese authorities had specifically requested the removal of these apps, the legal analysis Apple relied on to determine that it was required to remove the apps, whether it considered China’s human rights obligations in its analysis, whether it objected to the application of Chinese law or raised non-legal concerns with authorities, and what processes it had for making the 53