California Superior Court Judgment — Full Recognition in Zhejiang

Background: A California superior court entered a $4.2 million judgment in favor of a U.S. technology corporation against a Chinese manufacturer for breach of a supply agreement. The debtor had substantial assets in Zhejiang Province but refused to pay voluntarily.

Challenge: At the time, no bilateral judicial assistance treaty existed between China and the United States. Recognition depended entirely on the principle of reciprocity — and Chinese courts’ reciprocity practice was still developing.

Strategy: We identified favorable reciprocity jurisprudence from the same intermediate court and prepared a comprehensive application demonstrating that U.S. courts had previously recognized Chinese judgments. We also traced the debtor’s assets — corporate bank accounts and owned real estate — and filed a concurrent property preservation application to prevent dissipation.

Outcome: The Zhejiang intermediate court granted full recognition of the California judgment, accepting our reciprocity argument. The property preservation order froze the debtor’s assets. Post-recognition, the enforcement bureau levied bank accounts and recovered the full judgment amount plus interest within four months.

Significance: This case contributed to the growing body of reciprocity-based enforcement precedent in Chinese courts and demonstrated that U.S. money judgments are enforceable in China when properly presented.