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On February 9, 2026, the U.S. Department of Justice (“DOJ”) filed a complaint in the U.S. District Court for the District of Columbia to enforce a presidential order (the “Order”) requiring a Chinese company, Suirui Group Co., Ltd., and its Hong Kong subsidiary, Suirui International Co., Limited (collectively, “Suirui”), to divest their interest and rights in Jupiter Systems, LLC (“Jupiter”), a California-based company specializing in video processing technology.

This landmark action represents the first enforcement case of its kind filed in federal court, marking a significant development in the Committee on Foreign Investment in the United States’ (“CFIUS”) enforcement history. The action demonstrates CFIUS’s willingness to pursue judicial remedies when foreign investors fail to comply with presidential divestment orders.

Factual Background

President Trump originally issued the Order on July 8, 2025 requiring Suirui to divest their interest and rights in Jupiter. Our previous summary of the Order is available here. The Order followed a post-closing CFIUS review of Suirui’s acquisition of Jupiter in 2020. Through that review, CFIUS identified national security risks arising from Suirui’s ownership of Jupiter, particularly risks stemming from the use of Jupiter’s products in the military sector and in U.S. critical infrastructure, which could be compromised under Chinese ownership. The Order required Suirui to divest, and to ensure that its affiliates divest, within 120 days after the date of the Order unless an extension was granted by CFIUS, all equity and assets, both tangible and intangible, in Jupiter.

DOJ Complaint

On February 9, 2026, DOJ filed a complaint under the Defense Production Act (50 U.S.C. § 4565(d)(3)) to enforce the Order. The complaint names Suirui Group Co., Ltd., Suirui International Co., Limited, and Jupiter as defendants (collectively, “Defendants”), alleging that Suirui failed to comply with the Order and continues to hold equity in and assets of Jupiter.

According to the complaint, since issuing the Order in July 2025, the Departments of War and Treasury engaged with Suirui and Jupiter through weekly meetings and in-person site visits to monitor divestment efforts and prevent Suirui’s access to sensitive assets. The complaint explains that on September 23, 2025, Suirui requested a 90-day extension of the divestment deadline. The Departments of War and Treasury granted a 60-day extension to allow progress toward divestment. After a second extension request, the Departments of War and Treasury extended the deadline to February 3, 2026, with the caveat that further extensions would only be contemplated if, by January 20, 2026, Suirui provided a comprehensive term sheet reflecting terms for a transaction that would fulfill the terms of the Order.

The complaint alleges Suirui failed to meet both the January 20, 2026 term sheet deadline and the February 3, 2026 divestment deadline. As a result, DOJ asserts that Suirui violated the Order because (i) Jupiter remains a Suirui subsidiary and (ii) Jupiter continues to hold interests or rights in the assets or operations of the Jupiter Asia Companies acquired or created after completion of the original transaction.[1] 

In the complaint, DOJ seeks a declaration that Defendants failed to comply with the Order and 50 U.S.C. § 4565 (CFIUS’s statutory authority). DOJ also seeks to (i) enjoin Suirui from owning or controlling Jupiter’s equity and assets; (ii) enjoin Jupiter from being owned or controlled by Suirui; and (iii) obtain an order directing Suirui to divest itself of Jupiter’s equity and assets. Most significantly, DOJ requests an order transferring Jupiter’s equity and assets held by Suirui to a third-party fiduciary pending a transaction compliant with the Order. If granted, this remedy would effectively remove the Defendants’ control over the divestment process and place it with a court-appointed fiduciary.

Broader Implications of the DOJ Lawsuit

As the first federal enforcement action to compel divestment under a CFIUS order, DOJ’s complaint sends a clear message that presidential orders will be enforced through all available legal means. As this litigation proceeds, DOJ will establish an important precedent for CFIUS enforcement and demonstrate the U.S. government’s willingness to deploy its full enforcement toolkit. The complaint also serves as a reminder that transactions introducing Chinese investment in sensitive sectors may face substantially higher scrutiny and divestment risk, particularly when parties fail to seek CFIUS clearance proactively.

[1] At the time of the acquisition by Suirui, Jupiter was a Delaware LLC and had one subsidiary, Jupiter Systems China (Hong Kong) Ltd., a Hong Kong holding company that directly wholly owned Jie Xian Tong Computer Systems (Shenzhen) Co., Ltd. (collectively “Jupiter Asia Companies”).