Demand Letter Before Suing a Chinese Company: Strategy and Service Risks

A demand letter can clarify facts, trigger settlement, or preserve admissions. But in a China-US dispute, it should be drafted with filing, Hague service, jurisdiction, and evidence preservation in mind.

Not a substitute for service

A demand letter, email, or courier copy usually does not replace Hague Convention service in China.

Useful admissions

Responses can confirm entity identity, address, contract terms, payment promises, or authority problems.

Timing matters

A demand process should not allow service deadlines, limitation periods, or asset movement to overtake the case.

What a demand letter can accomplish

A focused letter can identify the dispute, preserve the plaintiff’s position, request documents, demand payment or performance, and test whether the Chinese company will negotiate before litigation costs increase.

What to avoid in China-US disputes

Avoid vague threats, wrong entity names, unsupported damages numbers, inconsistent forum statements, or language suggesting that informal notice is enough. A later Hague package and complaint should not contradict the demand record.

How demand responses become litigation evidence

Replies may confirm addresses, authorized representatives, payment history, quality issues, shipping facts, settlement offers, or refusal to cure. Preserve original emails, attachments, messaging app exports, and courier records.

Attorney review point

If the case is already filed, coordinate the demand strategy with Hague service timing and court deadlines instead of letting informal negotiation replace formal service.

Common Questions

Should a demand letter be sent before suing?

Sometimes. It can support settlement and evidence collection, but counsel should evaluate deadlines, asset risk, and whether the letter may alert the defendant.

Does a demand letter count as service in China?

Usually no. A demand letter or courier copy is informal notice and normally does not replace Hague Convention service for a China-based defendant.

What should be preserved after sending a demand?

Preserve the final letter, delivery records, email headers, attachments, replies, payment proposals, admissions, and any address or entity corrections.