Practice领域
Merger Control & Multi-Jurisdictional Filing
Chinese merger filings, multi-jurisdictional filing obligation analysis, transaction timing, competitive effects arguments, regulator engagement and conditional approvals — designed around deal structure, relevant markets, data methodology and cross-jurisdictional timelines.
Antitrust Investigations & Compliance
Investigation response, leniency applications, and compliance systems that translate abstract rules into governance mechanisms business teams can execute, document, review and explain.
Platform Economy & Digital Markets
Analysis of platform rules, data capabilities, algorithmic mechanisms, traffic allocation and user choice — competition law assessment and governance pathways for exclusivity, differentiated pricing and related conduct.
China Outbound & Global Competition Policy
Antitrust risk management for Chinese companies expanding overseas. Outbound compliance is not a "foreign law question" — it is part of global deal structure, distribution models and dispute strategy.
Representative Experience代表性项目
The matters below are described on an anonymized basis, in accordance with confidentiality obligations — only the nature of the matter, the regulatory procedure and the role are stated; no identifiable client or case information is included.
Largest EDA Industry Merger · Monitoring Trustee
Serving as monitoring trustee in the acquisition of a global engineering simulation software leader by a global EDA software leader — the largest merger in the history of the EDA industry. The role covers reviewing remedy implementation plans, verifying compliance data, reporting periodically to the regulator, and coordinating divestiture execution and cross-jurisdictional remedy alignment. Conditions attached include continued supply of key products, FRAND licensing, interoperability, non-bundling and structural divestiture.
First Conditional Approval of an SOE Merger in China · Monitoring Trustee
Monitoring trustee in the first Chinese merger case involving a state-owned entity approved with conditions. Over an eight-year monitoring period, supervising the full-scope antitrust compliance of an airport operator, an air logistics company and their joint venture — covering coordination risk across the parties' overlapping businesses and protection of third-party competition.
Global Non-SEP Patent Portfolio Operation · Antitrust Analysis
Antitrust analysis and compliance guidance on the global operation of non-standard-essential patent portfolios for three leading global energy companies — assessing competition law risk across patent co-ownership, centralized operation, split operation and cross-licensing models, and coordinating competition counsel in over thirty countries and jurisdictions toward a globally consistent, locally compliant operating framework.
Other Experience
Investigation response (abuse of dominance, bid-rigging, cartels — with significant fine reductions achieved in multiple matters, including the follow-on China proceedings of an EU high-voltage cable cartel case); internal investigations (including a post-dawn-raid investigation in China and price-fixing investigations); distribution and vertical restraint compliance across multiple industries (including RPM information requests); rollout of antitrust compliance policies across 13 Asia-Pacific jurisdictions for a global pharmaceutical company; compliance systems for utilities SOEs and financial institutions.
About关于
Frances Xu holds a PhD in economic law (competition law) from East China University of Political Science and Law and an LLM in International Business Law from the National University of Singapore. She previously served with the Competition and Consumer Policy Branch of the United Nations, working on global competition policy and consumer protection issues, and practiced antitrust at an international law firm's China joint operation platform before leading the competition practice at FuJae Partners.
According to FuJae Partners' public profile, she contributed to the drafting of the State Council's Opinions on Establishing a Fair Competition Review System, the Anti-Monopoly Compliance Guidelines for Business Operators, and the national standard Fair Competition Compliance Management for Business Operators (GB/T 45205-2024).
Perspectives代表观点
- Antitrust is not merely applying statutes — it is understanding how market structure, commercial logic, economic incentives and regulatory instruments relate to one another.
- The key question in merger control is not only whether thresholds are met, but whether the deal structure, control arrangements, relevant markets, data methodology and the regulator's real concerns are understood.
- Horizontal coordination risk lives not only in written agreements — trade association meetings, information exchange, price signalling and enforcement feedback mechanisms can all support concerted conduct.
- The core of multi-jurisdictional competition analysis is making the regulatory logic, evidence standards and deal timelines of different jurisdictions visible on the same map.
- The value of a compliance system lies in converting abstract legal rules into governance mechanisms that business departments can execute, document, review and explain.
Writing公开写作
China: Beyond the Agreement — Cartel Enforcement Moves to Coordination Architecture
On China's cartel enforcement shifting from locating explicit agreements toward identifying broader coordination architectures — and why companies must examine external communications, trade association participation, sales practices, data flows and internal decision-making. Also at GCR.
Media & Speaking媒体与演讲
Shanghai TV "Xinwen Yexian" Interview Series
Interviewed on differential treatment between new and existing subscribers in telecom tariff plans (June 17), food-delivery platform subsidy regulation (June 22), and the Chinese iOS developers' complaint against Apple (June 26) — analyzing the regulatory and market mechanisms behind consumer-side controversies.
Professional Training & Academic Lectures
Shanghai Bar Association merger control practice training (2025), cross-border antitrust risks for Chinese companies going global (2025), hub-and-spoke agreements under the amended AML (2022), CIETAC China Arbitration Week (2021), and the ECUPL summer program on foreign-related rule of law, "Global Perspectives on Antitrust and Fair Competition" (2026).
Awards主要荣誉
Recognition荣誉与评级
Contact联系
Email: frances.xu@fujae.com
Firm: FuJae Partners, Shanghai