Michael Norris is a TechNode contributor and Research and Strategy lead at AgencyChina. Commentaries do not necessarily represent the editorial position of TechNode.

Dear TikTok PR,

TikTok is in a unique and delicate position.

On the one hand, you’ve got a breakout hit. Sensor Tower reports that, outside games, TikTok is the most downloaded app of the year and the only app in the top five that isn’t owned by Facebook. This, alongside the success of Douyin, TikTok’s predecessor in mainland China, is cause for congratulations.

On the other hand, your success has brought scrutiny, especially in the US. I suspect you’ve been busy since Reuters reported on an ongoing national security investigation into Bytedance’s 2017 acquisition of Musical.ly. This review, undertaken by the Committee on Foreign Investment in the United States (CFIUS) could, at worst, compel you to reverse the merger that brought TikTok to the US.

But, even before CFIUS got involved, you routinely found yourself caught in blunders and backflips.

First, leaked documents showed TikTok created guidelines to remove content that could offend the Chinese government. You said those guidelines had been superseded, but former employees promptly contradicted these claims.

Then, you massaged over changes to TikTok’s org structure. I can only presume changes to Alex Zhu (Head of TikTok)’s reporting line were intended to create distance between TikTok and Douyin. However, the change (whereby Alex reports to Bytedance CEO Zhang Yiming) make it look like Alex literally and figuratively takes orders from Beijing. Speaking of, a few days ago you thought it would be wise for Alex to cancel meetings with US lawmakers critical of TikTok. It’s still early days, but I anticipate you’ll take some heat for that.

All this all while TikTok backflipped on blocking a US teenager sharing her views on internment of Muslims in Xinjiang and was caught with its pants down again choking traffic to content creators with disabilities, plump body shapes and pro-LQBTIQ views.

So here’s a heads up: there are three reasons why your PR quagmire will get worse in the coming year.

First, you haven’t developed a coherent narrative to assuage fears around Chinese ownership.

Jingoistic politicians aren’t your fault, but you’ll have to go all-out to add substance to your claims that TikTok’s management, operations, apps, markets, users, content, teams, and policies are separated from Chinese government interference.

That’ll be made difficult by your connections to the Chinese Communist Party. These connections spur Bytedance to censor sensitive videos, collaborate with party-related organizations, promote videos praising China’s armed forces and de-tag videos which contain particular political figures.

There’s also the question of TikTok’s workforce. Someone will presumably go on LinkedIn and work out that around one in ten TikTok employees listed are based in China, as of Dec. 18. From the same data set, they’ll also notice that there are very few folks in the US responsible for product, and even fewer responsible for content moderation. These optics are, in a word, bad.

Second, TikTok’s previous content-related SNAFUs will prompt rigorous inspection of its Community Guidelines. These are far, far shorter than what Facebook has developed, and that company is still a long way off getting out of PR purgatory. I know you’ve hired lawyers and former congressmen to pad them out, but I’m not convinced how far “Bear with us, we’re working on it” will go with American officials.

During this process, I anticipate you will be asked to detail how Bytedance and TikTok use human moderators and machine learning to identify, classify, demote and remove offensive content. You might not feel the need to do this, but there are folks out there who are already putting the pieces together. You should take the initiative and show how you deploy human and machine-assisted moderation to block nudity, combat ISIS propaganda and report potential sexual predators.

It’s at this point that, someone, somewhere, will look closely at the nexus between TikTok and Douyin.

You see, it’s no secret that it was only very recently TikTok divorced itself from Douyin’s product team.

It’s also no secret that Douyin’s CEO pledged to use the platform “curate” content around positive values (Chinese), which weren’t named or articulated. The existence of similar editorial or curatorial policies in your overseas markets may be all that’s needed to convince investigators that TikTok could be a vehicle for foreign influence.

There you have it. A full suite of reasons why you’ll be pushing the proverbial uphill in the coming year.

Getting on top of each of these areas may very well be critical for your continued operations in America. CFIUS hasn’t looked too kindly on Chinese tech companies in the recent past, and it appears to be responsive to anti-China sentiment in Congress. For instance, it made a Chinese acquirer sell Grindr, blocked the sale of MoneyGram to Ant Financial, and also prohibited the sale of a US semiconductor firm to a Chinese government-backed investment firm back in 2017.

You’re at real risk of losing the PR battle, which could mean orders to divest Musical.ly and potentially exit your most lucrative overseas market.

You’ll have your work cut out. Good luck.

Michael Norris

Michael Norris is a TechNode contributor and Research and Strategy lead at AgencyChina. He focuses on how culture, technology, and digital trends affect industry and business. Michael is a TechNode Insider.

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