This memorandum analyzes a declaration submitted to the Federal Communications Commission in May 2018 by two attorneys from the Zhong Lun law firm in China. The declaration supports Huawei's position that it cannot be compelled under Chinese law to tamper with telecommunications equipment it manufactures or sell to install backdoors, eavesdropping facilities, or other spyware. The memorandum finds the declaration to be incomplete, in that it does not address the key question of the extent to which the Chinese government is constrained by Chinese law. It also finds that the declaration makes some questionable assertions about Chinese law.