Recently, the State Administration for Market Regulation released a batch of typical trade secret cases, and the case handled by the Hangzhou Municipal Market Regulation Bureau involving China’s first trade secret case concerning a vertical artificial intelligence large model was selected. In this case, Sun disclosed relevant technical materials to a Hangzhou Technology Co., Ltd., which is controlled by him, during his employment, such as the rights holder’s exclusive prompt templates for the large model, review rules, and annotation specifications, and used them for the party’s development of the relevant artificial intelligence large model. With reference to the special demonstration opinions of industry experts, the handling agency determined that the integrated scenario-based intelligent review solution formed by the combination of the above materials possessed the elements of non-publicity, commercial value, and enterprise confidentiality control, and constituted a new type of integrated technical secret.

In May 2026, the Hangzhou Municipal Market Regulation Bureau determined that Sun had violated the relevant provisions of the Anti-Unfair Competition Law of the People’s Republic of China (2019 version), ordered him to stop the illegal acts, and imposed a fine of 350,000 yuan. In July 2026, it determined that Hangzhou Technology Co., Ltd. had violated the relevant provisions, ordered it to stop the illegal acts, and imposed a fine of 150,000 yuan.

Staff of the Hangzhou Municipal Market Regulation Bureau explained that with the rapid development of artificial intelligence large models, new types of technical information such as prompt engineering and agent skill packages are constantly emerging. Traditional intellectual property rights such as patents and copyrights are difficult to match their development characteristics, and a large amount of technical information is protected in the form of trade secrets.
 
As China’s first administrative enforcement case involving trade secrets of a vertical artificial intelligence large model, this case is a landmark case of market regulation departments, based on the new development situation of the artificial intelligence industry, precisely performing their duties and innovating in law enforcement. (October 8, 2026, Daily Business)