The 2019 UN IGF is right now being held in Berlin and entering the last day. There has been a wide range of exciting discussions. It is a huge step forward that this year’s IGF has been able to bring a plethora of topics together under a framework of thinking after the efforts done by the UN Secretary-General António Guterres’ High-Level Panel on Digital Cooperation (The Age of Digital Interdependence) and by German scholars’ engagement with all the stakeholders (Towards a Global Framework for Cyber Peace and Digital Cooperation: An Agenda for the 2020s).

A central underlying topic of this year’s IGF is about the conceptions about digital sovereignty. It is totally predictable that Chancellor Merkel would use Berlin Wall metaphor to enshrine the value of free speech. It is rare, however, to hear that she emphasizes digital sovereignty, which is said to be neither censorship nor protectionism, but a way through which individuals are capable of determining their own digital development.

Sovereignty in cyberspace has long been labeled by Western mainstream literature as a “monopoly” by China. But this is no longer the case, perhaps has never been. This column piece wants to share a different narrative: Washington DC is, in reality, the strongest supporter of the notion of cyber sovereignty in the military domain; China pays more attention to the content category; EU is more concerned about big tech giants.

Or, an easier way to put it might be this. All nations and every individual like nice words and they all support freedom and free flow. The important thing is how they make exceptions. China has social stability exceptions. U.S. has national security exceptions. Germany has privacy exceptions. All the three nations, however, attach great importance to political stability, who is the core for a society to function.

I shared my ideas in the IGF 2019 Digital Sovereignty & Internet Fragmentation session. (https://www.youtube.com/watch?v=p55_LZmJ-2o&t=3795s). Below is a rewriting of what I said about how national sovereignty has made its extensions into cyberspace—with different degrees, in different categories, by different stakeholders—which shapes the complexities and contradictions in the articulation of digital sovereignty by different nations and stakeholders. There are five contexts.

Category No. 1 Military or legitimacy of cyberspace as military domain and the rules for it if it is legitimate. We see in this category the most hardcore extension of traditional national sovereignty into cyberspace by some nation-states. You will be given a Nobel Peace prize if you can find a multi-stakeholder solution to this unilateral or multilateral issue. If we can reduce the tensions in this category, all the rest of the challenges will become irrelevant and evaporate. China remains reluctant to admit that cyberspace has become a military zone but still eagerly promotes national sovereignty for defensive purpose against the possibility that the same two words—national sovereignty—might be used for offensive purposes by some other countries. That is a rather paradoxical situation.

Category No. 2 Crime or cybercrime governance. This is also a sovereignty story, but there are some transnational initiatives and mechanisms installed. EU has the Budapest Convention on Cybercrime. Russia has submitted a UN Convention on the Fight against Information Crimes. U.S. and UK have signed the first bilateral data-sharing agreement under CLOUD. China follows a practical approach and is busy taking back suspects committing telecommunication fraud from abroad. Cybercrime is now No.1 type of crime in China, which is also good news because the crimes in the streets have significantly reduced.

Category No. 3 Trade or digital economy and digital trade rules. The most recent update is Osaka Track. It is another challenging field that brings together a lot of elements that call for multi-ministry and multi-stakeholder coordination. This is where free flow is upheld and may lead to the removal of many practices of data localization. The word trust in the principle of “data free flow with trust” is problematic and subjective. A plain use of free flow is much clearer.

Category No. 4 Code or technical communities and management of core Internet resources. This is where institutional innovation really happens and should be more widely exported to inform other categories. China is happy about the current situation. Multi-stakeholder is firmly supported. The words have been spread and repeated by Chinese President for quite some years at the World Internet Conference WuZhen Summit. All the WuZhen gatherings have carried a theme of “Digital Commons.” The values nurtured by the technical communities are highly appreciated and resonate with some universal values deeply rooted in Chinese culture. The Chinese philosopher Zhao Ting-yang captures this Chinese worldview in his books about global governance. He concluded his dialogue with his French counterpart Régis Debray that the Internet changed the world more than revolutionaries like Marx, Lenin, and Mao Zedong.

Category No. 5 Content or social media governance. China so far prefers a sovereignty approach in this category. But domestically, It is important to pay attention to the diversity of media ownerships in China. There are state media like People’s Daily. There are commercial media such as Tick-Tok. There are grassroots media like half a billion users’ Microblog or WeChat accounts. The rise of private media ownership is quite reassuring.

Therefore, there are different extensions and projections of national sovereignty in different cyber contexts. A U.S. military version of hardcore cyber sovereignty assumes certain enemies, bases itself basically purely on imaginations, and makes China and perhaps many other developing parts of the world feel extremely uneasy. However, the Chinese way of protecting cyber sovereignty in the content domain makes the U.S. cry foul over human rights principles.

German Chancellor Merkel and her more outspoken French counterpart President Macron share the same U.S. worries about Chinese domestic practices in the content domain, but are more urgently concerned about the big U.S. Internet platforms, and this is perhaps the direction of a European version of digital sovereignty is pointing to. All of these are further enhanced by the uncertainties and competition for huge opportunities brought by emerging technologies.

Solution: return to the insights and values of the Founding Fathers of the Internet and flexibly combine multistakeholderism and multilateralism in global digital policy-making.