What are the most significant cases, transactions or projects that your legal team has recently been involved in?

As ByteDance’s flagship product in Japan, TikTok has launched various features throughout the last year, and numerous partnership projects, including but not limited to TikTok Now, TikTok Gated Live, TikTok TV, TikTok Toho Film Festival, Buzz Tracker and TikTok Creative Festival. TikTok has been widely accepted by Japanese users and has become one of the most popular apps worldwide. To fulfil our mission to ‘inspire creativity and enrich lives’, we continue to expand our business to become the most trusted platform. As ByteDance/TikTok Japan’s first legal counsel, I took the initiative to build the legal department from scratch and now I serve as the lead product counsel, leading my team to support all the aforementioned projects and operations from the legal perspective. In order to boost the strong development and growth of TikTok, my team is responsible for drafting and reviewing contracts, negotiating with relevant stakeholders, conducting compliance reviews and providing other legal advice.

Could you share an example of a time when your team came up with an innovation that improved how your legal team works and did not come at a large expense?

For example, the virtual currency published on TikTok (TikTok Coins) needs to comply with regulatory procedures under the Payment Services Act, and after the initial notification procedure was completed in 2020, my team and I have continued to carry out periodic reports and relevant procedures. In addition, in order to respond to data disclosure requests in accordance with the revised act on the Limitation of Liability for Damages of Specified Telecommunications Service Providers and the Disclosure of Sender Information, my team has taken the lead in establishing an internal system involving stakeholders across different departments to respond to requests for disclosure of sender information, which has greatly contributed to making TikTok a more reliable platform. As is common in these cases, the legal team researched what the law required of business operators, understood the procedural details in accordance with the law and practice, and advised the internal cross-departmental teams on what to do and how to do it in a simplified but precise manner. While there is no silver bullet, we persistently communicate with other teams and seek their cooperation to build a strong and legitimate structure that will help us acquire public recognition and trust.

How important is choosing to work with external lawyers who align with your company’s values?

Close collaboration with external lawyers plays a substantial role on a daily basis. It is also important to ensure that business objectives are met through excellent collaboration and that responsibilities are shared appropriately. The primary strength of external lawyers in large law firms is that they have vast resources, cover a wide range of legal areas and have profound expertise in specific areas. For boutique firms, on the other hand, we expect them to provide faster and more flexible advice which allows us to handle day-to-day business smoothly and accurately. In rapidly changing industries such as technology, media and telecommunications, it is crucial to keep pace with new legislation and practical cases. We also subscribe to legal publications and newsletters published by law firms and attend external legal seminars and summits. In regard to the criteria, we maintain for choosing external lawyers to work with, we expect them to offer in-depth industry-specific knowledge or to have distinguished experience in our industry.

How do you suggest in-house lawyers build strong relationships with business partners?

Firstly, a deep understanding of the partner’s business and industry is essential for in-house lawyers to add value. Our group companies have products and services that span a variety of industries, requiring them to keep up with the dynamic changes in trends and practices in their respective industries. We encourage legal teams to demonstrate an eagerness to learn through open dialogue, constructive criticism and mutual respect. Secondly, I believe that our key role is to be visible and proactive in helping our partners resolve disputes and mitigate legal risks by achieving optimal levels of performance and results while taking on a wide range of responsibilities in various situations. Specifically, the legal team should develop and implement policies and procedures to improve risk management, compliance and governance across the organisation, ensuring that legal and regulatory requirements are met, and the company is protected from exposure. In-house lawyers should conduct training on legal and regulatory issues, foster a culture of compliance, and raise awareness of legal risks and obligations. In addition, we collaborate with external counsel, regulators and industry groups to stay informed about changes in legislation and regulation, providing guidance to the company on best practice, emerging issues, and strengthening good relationships with effective communication. I am confident that my team has provided viable legal solutions in multiple languages with exceptional communications skills, handled the negotiation and execution of several high-value commercial contracts, which has resulted in increased revenue and improved partnerships.