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How to Use Voice Typing on Google Docs on Mobile and Desktop

Paurush dabbles around iOS and Mac while his close encounters are with Android and Windows. Before becoming a writer, he produced videos for brands like Mr. Phone and Digit. On weekends, he is a full-time cinephile trying to reduce his never-ending watchlist, often making it longer.

While Google Docs is primarily geared toward drafting formal letters, invites, meeting notes, and table of contents , you can also use it to jot down ideas or as a journal. To that end, Google Docs is quite feature-rich and supports features like Voice Typing which makes penning down thoughts more convenient.

The Voice Typing feature eliminates writer’s block by allowing users to jot down rough and unstructured ideas. You don’t have to waste your time thinking of writing perfect sentences – instead, you can just voice your thoughts, scattered as they may be. Here’s how to enable the feature and use it on your mobile and desktop.

Use Voice Typing on Google Docs on Mobile

The Google Docs mobile app lets you manage your documents on the go. The app lets you edit your documents and even save them as PDF files on your iPhone or Android phone. Let us see how you can use the Voice Typing feature with the mobile app.

iPhone users can simply use the Speech-to-Text feature available with the iOS Keyboard to use Google Docs’ Voice Typing feature. Here’s how.

Step 1: Open the Google Docs app and then open a new or previously created document.

Step 2: Tap on the page to bring up the keyboard. Then, tap the Microphone icon at the bottom-right corner.

Step 3: Start dictating the words, and Google Docs will convert the speech to text.

If you don’t see the Microphone icon, check if Voice Dictation has been enabled. Here’s how you can go about it.

Step 1: Open the Settings app and then tap on General.

Step 2: Select Keyboard and tap the toggle next to Enable Dictation.

You can also enable Auto-Punctuation and tweak other aspects from the same menu.

If Dictation still fails to work, refer to our post for more solutions. Note that the solutions outlined in the guide will apply to all iPhones on all iOS versions.

Step 1: Open Google Docs and select a new or previously created document.

Step 2: Tap on the document area to enable the keyboard. Then tap the Microphone icon.

You can refer to our post if Dictation fails to work on your Android phone .

Use Voice Typing on Google Docs on Desktop

For desktop users, the Voice Typing feature comes built-in with Google Docs. However, it is only available for Google Chrome and Microsoft Edge users on Mac and Windows PCs. Here’s how to enable and use it.

Step 1: Open your web browser and go to docs.google.com.

Visit Google Docs

Step 2: Sign in to your account and open a new or existing document.

Step 3: Click on Tools in the top Menu Bar and then select Voice Typing.

Step 4: Select the Microphone icon on the left side. Your browser will then prompt you to enable microphone access. Tap Allow.

You can also click the dropdown menu and select your preferred language.

And voila! You can now start using Voice Dictation on your Mac or Windows PC in Google Docs.

How to Use Punctuation and Formatting Styles With Voice Typing

The best part about voice typing on Google Docs is that you can also dictate and insert punctuation. This saves you the time of manual entry and correction. Once you enable the microphone, you can start voicing commands like “select all”, “bold”, “italics”, and more. There are a plethora of other voice commands available for voice typing. A word of caution, though: your dictated punctuation might not always get translated correctly. So, be patient while using the feature.

Use Microsoft Voice Typing Launcher For Google Docs on Windows 11

Windows 11 has a feature called Voice Typing Launcher (Microsoft Speech Services) that is designed to be used for voice typing. You can activate this feature to use voice typing on Google Docs or any other application. Before following the steps to enable it, make sure that you have installed the latest software update.

Step 1: Open Google Docs on your web browser and sign in to your account.

Step 2: Go to your document and press Windows key + H to enable Microsoft Speech Services.

Step 3: From the popup, click the Microphone icon to start using it.

You can click the Settings icon to make changes, including using a different microphone and enabling automatic punctuation. We tested the same on our end and the service introduced commas and full stops automatically, which is great.

You can also refer to our post if Voice Typing is not working on Windows 11 .

Use Dictation on Mac For Voice Typing on Google Docs

You can also use the Dictation feature on Mac to facilitate Voice Typing. It’s a built-in tool that lets you use speech-to-text in Google Docs. All the voice commands for using punctuation will work with this, too. You can refer to our post to learn how to use Dictation on Mac .

Rest Your Fingers

The Voice Typing option on Google Docs is a much-needed respite from endless typing sessions. The feature can also come in clutch when you need to take note of something while juggling other tasks. Let us know if you found this guide useful in the comments below.

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Last updated on 16 March, 2024

The above article may contain affiliate links which help support Guiding Tech. However, it does not affect our editorial integrity. The content remains unbiased and authentic.

The article above may contain affiliate links which help support Guiding Tech. The content remains unbiased and authentic and will never affect our editorial integrity.

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How to use speech-to-text in Google Docs

Accessible and easy to use speech-to-text software

Speech-to-text software has come along way in recent years. We remember even a few years ago when voice typing required strange voices and mouth movements that looked like they belonged in a Saturday Night Live sketch. 

Today, however, more and more businesses are incorporating voice typing into their business operations. It can be an easy way to save time and increase the productivity of your employees and can be crucial in making your business accessible to persons with disabilities.

In this article, we explain how to use voice typing software on Google Docs. Although it is not the best speech-to-text software , it is free and easy to use, and will serve many businesses’ purposes.

How to use speech-to-text in Google Docs: Preparation

Google’s speech-to-text software currently only works on the Google Chrome browser. If you already use Chrome, you won’t need much preparation at all, and you won’t have to download or install any additional software or plugins. However, if you don’t have Chrome, you’ll have to download it via this link . 

The only other thing you’ll need to do before you can begin using Google’s speech-to-text software is to set up your microphone. Using the in-built microphone on your device will suffice most of the time, as Google’s dictation software has improved significantly in recent years.

However, if you’re planning on dictating a lengthy text, or plan on using Google’s dictation software every day, we’d consider investing in a high-quality microphone. An external microphone will enable Google to interpret your voice more easily and can be placed in an optimal location.

Once you’ve downloaded Chrome and prepared a microphone , you’re ready to go.

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Step 1: Open a new Google Docs file

Open Google Chrome on your device and head to the Google Docs website. If you’re not currently logged into your Google account, go ahead and log in now. 

After you’ve logged in, create a new Google Doc. For our test, we named it “Speech-to-text in Google Docs - Test”. Ensure you save the article in a location where you’ll be able to access it later (to either edit or delete it).

Step 2: Open the voice typing window

Within this blank document, you should be able to see the menu options at the top of the window. To begin voice typing, click on the Tools menu option and then Voice Typing. You can also open the Voice Typing window by using the keyboard shortcut Ctrl+Shift+S.

Step 3: Grant Google Docs access to the microphone

If you’ve never used Google’s speech-to-text software before, you’ll need to grant the platform access to your microphone. On Google Chrome, this is a simple as clicking “allow” when prompted. 

Once you’ve clicked “allow”, the microphone symbol will change to red. Congratulations –you’re now using voice typing!

Step 4: Begin voice typing

With the microphone symbol changed to red, you can now begin speaking in a natural voice and watch as Google transcribes your voice to text. Unlike with older speech-to-text software, there’s no need to speak robotically, or at a comically slow pace. Google’s dictation software is designed to understand natural speech. Our only suggestion is to clearly enunciate lengthier or more complicated words, as these are where the software most often struggles. 

Following these four steps alone will enable you to begin voice typing, saving time and energy that could be better spent elsewhere. After playing around with the software, you’ll quickly become comfortable with it and develop your own strategies for accurate and reliable transcription.

However, if you want to take your voice typing to the next level, read on to discover some of Google’s advanced voice commands.

Step 5: Voice commands

Google Docs also features several voice commands that enable you to create professional documents using only your voice. We’ll now explore a few of the most useful commands, but you can find the full list here .

The voice commands you’ll use most often are mostly self-explanatory. Saying the command “period” will insert a period into your document, while saying “bold” or “italic” will change the style of text correspondingly. 

Formatting is also simple using commands such as “insert page break”, “insert horizontal line”, or “insert heading”, among many others. 

Users can also change the text color by saying “text color (insert color)”. 

Developing a mastery of these voice commands enables you to make the most of Google’s speech-to-text software, and ensures you and your employees can work faster and more effectively when voice typing. 

Voice typing software has improved dramatically in recent years. In the past, businesses had to invest in expensive dictation software if they wanted a functional voice typing experience. And even then, there were limits on what such software could achieve. 

Today, Google’s voice to text software enables businesses to incorporate voice typing into their operations free of charge. The software certainly isn’t the best available, but for most organizations, Google’s voice typing will more than suffice. We think that the extensive list of voice commands make the software appealing for employers and employees alike. 

• We list the best text-to-speech software .

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How to make Google Docs read your documents out loud to you, using a Google Chrome extension

• You can make Google Docs read text to you out loud with the text-to-speech function.
• You'll need to use the Google Chrome web browser, along with the ChromeVox extension, which will read the text of any webpage aloud to you.
• Visit Business Insider's homepage for more stories .

Sometimes a fresh perspective can make a world of difference. Hearing your written words spoken aloud, for example, can help you more easily find those spots that need refining or rephrasing. 

But for those who don't want — or simply don't have the option — to let someone else read them their work, Google Chrome's accessibility features can provide a good digital replacement. 

Here's how to set up the text-to-speech feature and have Google Docs read your text out loud:

Check out the products mentioned in this article:

Lenovo ideapad 130 (from $299.99 at best buy), macbook pro (from $1,299.99 at best buy), how to make google docs read text aloud to you.

In order for this to work, be sure that you've added the ChromeVox extension to your Google Chrome web browser on a PC or Mac computer.

1. Open your Google Doc.

2. Click "Tools" in the top toolbar.

3. Select "Accessibility settings."

4. Tick the box next to "Turn on Screen Reader Support" and then click "OK." You should now see a new section appear in your top toolbar called "Accessibility."

5. Highlight the section of text you want read aloud.

6. Click "Accessibility" and then "Speak," followed by "Speak selection."

ChromeVox will read the selection aloud to you.

Note, however, that if you have more than one Google Doc page open, ChromeVox may try to read from a different document. You should try this with only one document open at a time.

Related coverage from  How To Do Everything: Tech :

How to add a font to google docs in 2 different ways, how to run a spell check in google docs in 2 ways, to fix spelling and grammar errors, how to assign tasks in google docs in 2 different ways, how to change the language in google docs to translate a document or type in a different language, how to use grammarly on google docs with a google chrome extension to enhance your writing.

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We couldn't find what you are looking for, voice typing: transcribe audio using google docs.

A quick and easy way to convert audio to text.

Learn to convert audio to text using Google Docs.

This lesson will teach you to use the Voice Typing feature in Google Docs as a quick audio to text converter. It can help you improve your workflow by transcribing things like interviews and voice notes. 

Activate Voice Typing in Google Docs.

Begin transcribing your audio., troubleshooting poor audio quality., how to add punctuation., learn more about voice typing..

For more Fundamentals lessons, visit:  https://newsinitiative.withgoogle.com/training/course/fundamentals

Step 1 To activate Voice Typing in Google Docs, open a new or existing document and select Tools > Voice typing. A small floating box with a microphone icon will pop up.

Step 2 At the top of the box, a drop down menu lets you select the language you want to transcribe, including many variants of English, Spanish, Portuguese, and Arabic.

Step 3 To move the box to a convenient spot while you work, left-click on the top of the box and drag it.

Step 1 Once you've chosen a language, click the microphone and start speaking. Voice Typing will transcribe whatever is coming through your computer microphone.

Step 2 If you recorded an interview with your phone or a traditional recorder, hold it close to the computer microphone for playback. If the recording is clear enough, Voice Typing should be able to transcribe most of it with few typing mistakes.

Step 3 To pause the transcription, click the microphone. It will turn black to show that it’s paused.

If the recording is not clear, you can try plugging in your headphones and listening to the audio recording yourself. As you listen, repeat the words back to the computer in a clearer way. Voice Typing should be able to transcribe it.

You can use these phrases to add punctuation to your text: period, comma, exclamation point, question mark, new line, and new paragraph. The punctuation function works with a few selected languages, including German, English, Spanish, French, Italian, Russian, and Portuguese.

For help using Voice Typing or to learn more techniques, hover over the microphone box until a question mark appears, then click it.  

Congratulations!

You completed “Voice Typing: Transcribe audio using Google Docs.”

To continue building your digital journalism skills and work toward Google News Initiative certification, go to our  Training Center  website and take another lesson.

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How to speech-to-text in Google Docs

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When I struggle to write, I change something–I stretch or walk, stand instead of sit, or vice versa.

Sometimes I talk instead of type. I configure speech-to-text software to capture my voice, then just talk. I often end up with a bunch of text to edit. I find talking to be an excellent alternative to typing to capture not yet fully formed ideas.

Fortunately, I write with Google Docs, so there are several tools I can use to turn my voice into text.

Android: Google Voice Typing

The best voice recognition tool for Google Docs, Google Voice Typing ( Figure A ), used to be found only on Android devices. Install the Google Docs app, open a document, and tap the microphone icon located to the left of the space bar on the on-screen keyboard. Then talk. Google Voice Typing turns your speech into text.

On Android, Google Voice Typing turns speech into text accurately and quickly.

Chrome os: on-screen keyboard.

Google also includes speech recognition in Chrome OS as an accessibility option ( Figure B ). To enable it, select the three-line menu, choose Settings, scroll to the bottom of the page, and select Show advanced settings. Look for the Accessibility option to enable the on-screen keyboard. When the keyboard displays, select the microphone displayed above the on-screen keyboard to activate speech recognition.

On Chromebooks, enable the on-screen keyboard to access the built-in Chrome OS speech recognition system.

Google docs on the web: add-on.

A third-party Add-on for Google Docs on the web also enables Speech Recognition ( Figure C ). Unlike the on-screen keyboard, the Add-on works only within a Google Doc; the Chrome OS on-screen keyboard works with all text fields.

In Google Docs on the web, use the third-party Speech Recognition Add-on.

To install the Speech Recognition Add-on, open a Google Doc, choose Add-ons, and then select Get add-ons. Next, search for Speech, then choose the + Free button to add it. Every time you want to start voice recognition, go to the Add-ons menu, choose Speech Recognition, and click Start. A sidebar will appear to the right of your document. Choose your language and dialect, select the blue Start button, and then start talking.

Apple and Windows systems

Apple devices and Microsoft Windows systems also offer speech recognition options. Dictation on Apple mobile devices works much like Google Voice Typing on Android: tap the microphone to the left of the keyboard, then talk ( Figure D ). On Mac OS devices, turn on Dictation . Microsoft’s speech recognition system requires a settings change, followed by a brief training session for the system to learn your voice in Windows 7 , 8/8.1 , and 10 .

Apple also offers Dictation, which provides speech recognition on iOS that works with the Google Docs app.

Tip: say the symbol.

For accurate punctuation, say the symbol. These systems recognize common punctuation marks and terms. For example, take the following two sentences:

“In November 1660, 12 people met at Gresham College in London to talk about a common interest: science. The group met often to discuss experiments and share ideas, and it eventually evolved into what we now know as the Royal Society.”

To properly capture and punctuate these sentences, you’d say:

“In November 1660 comma 12 people met at Gresham College in London to talk about a common interest colon science period The group met often to discuss experiments and share ideas comma and it eventually evolved into what we now know as the Royal Society period”

Note how you use the terms comma, colon, and period. Terms like “new paragraph” also work.

Tip: On a Chromebook, a headset helps

I tested the control sentences above on my Toshiba Chromebook 2 with the built-in microphone and then with a Logitech G330 USB headset. I also tested the phrases with both the native Chrome OS speech recognition system and the third-party Google Docs Add-on.

When I used the headset, accuracy improved ( Figure E ). With the headset, the Chrome OS speech recognition system captured the phrases with 100% accuracy. Google Voice Typing in a Google Doc on a Samsung Galaxy Note 4 for the same phrases also achieved 100% accuracy without a headset.

Use a headset with a Chromebook to improve the accuracy of speech recognition.

Why do you use speech-to-text tools.

While I use speech-to-text to capture ideas, a colleague of mine uses speech-to-text to reply to email and texts. He doesn’t like typing on tiny touch screen keyboards, so he dictates his responses. He relies on the speech recognition software to get the message right. Most of the time, it does.

Speech recognition also helps people who experience pain when typing to communicate. A person I know with carpal tunnel syndrome chooses to talk instead of type whenever possible.

Have you tried Google’s speech recognition systems on your Chromebook or Android device? Where–and why–do you use speech-to-text tools? Let us know in the discussion thread below.

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How-To Geek

How to use voice typing in google docs.

Google Docs lets you use voice typing to dictate using your computer's microphone.

Quick Links

Google Docs lets you use voice typing to dictate using your computer's microphone . It's great for people who suffer from a repetitive strain injury, or for those who just don't like typing. Here's how to use Voice Typing in Google Docs.

Note:  Voice Typing is only available for use in Google Docs and the speaker notes of Google Slides, and only if you're using Google Chrome.

The first thing you're going to want to do is to make sure you have a microphone installed and working.

Once your microphone is set up, fire up Chrome and head on over to Google Docs . Alternatively, from the address bar in Chrome, type

to start a new document instantly.

Enabling Voice Typing

To activate Voice typing, click Tools > Voice Typing. You can also press Ctrl+Shift+S in Windows or Command+Shift+S in macOS.

A window with a microphone icon will appear; click on it when you're ready to dictate. You can move the tool out of the way by clicking and dragging the window wherever you want.

Note: The first time using Voice Typing, you'll need to grant Chrome permissions to use your microphone.

If Voice Typing doesn't automatically load your native tongue, click the three dots and then use the Language drop-down to select from over 100 languages and dialects.

Speak clearly in your normal volume and at your normal pace so the tool can understand what you're saying. Everything you say now appears in the body of your document. If it's having trouble understanding you, make sure you have selected the correct dialect in the languages menu.

Voice typing processes your voice in real-time. When you finish speaking, click the microphone again to stop listening.

Adding Punctuation

Voice typing even understands when you want to add punctuation to your document if you use these phrases:

• Exclamation mark
• Question mark
• New Paragraph

So, for example, you could say "Dictating in Google Docs is easy and fun period You can even..."

Note:  Punctuation only works in German, English, Spanish, French, Italian, and Russian.

Using Voice Commands

Using voice typing doesn't end with the ability to type words and add punctuation. You can use it to edit and format text and paragraphs inside your document without having to click anything in the toolbar.

Note:  Voice commands are only available in English for Google Docs; they are not available in Slides speaker notes. Both the account and document language must be English.

If you mess up and accidentally say something you want to be deleted, you can say "Delete" or "backspace" to remove the word before the cursor.

Here are some other useful commands to get you started being more productive and making the most out of Voice Typing:

• Selecting text: Select [word, phrase, all, next line, next paragraph, next word, last word]"
• Format your document:  Apply Heading [1-6], apply normal text, Bold, italicize, italics, underline
• Change font size:  Decrease font size, increase font size, font size [6-400], make bigger, make smaller
• Edit your document:  Copy, cut, paste, delete [word or phrase], insert [table of contents, bookmark, equation, footer, header, page break]
• Move around your document:  Go to start/end of [line, paragraph, column, row, document], move to next/previous [character, word, page, column, heading, line, misspelling, paragraph, row]

The number of voice commands almost seems endless, and you can find a full list by clicking the question mark in the tool's window or by saying "Voice commands list."

When you've finished with your document and no longer want voice typing to pick up any of the words you're saying, say "Stop listening."

Voice Typing and speech-to-text have come a long way in recent years and with the number of features, commands, and greater accuracy, you could use it to type all your notes---or even a whole document.

Voice Typing also helps people who suffer from carpal tunnel syndrome or otherwise experience pain when typing. Once you've mastered all the commands, you may never have to use a keyboard or mouse when typing up a document again!

An Easy Text to Speech Google Docs Tutorial [3 Ways]

• Last updated June 5, 2023

Google Docs is a great workspace that has plenty of tools and functionality to help all kinds of users. One such tool is Text-to-speech which enables the conversion of written text into spoken words. This opens up a whole new world of accessibility, convenience, and enhanced productivity.

Text-to-speech is a tool in Google Docs that is dedicated to helping the visually impaired work seamlessly on the platform, but it also has great benefits for every user.

Discover how to make your written content come alive, improve your proofreading skills, enhance language learning, and make information more accessible to a wider audience.

In this Text to speech Google Docs tutorial, we’ll show you how to use text-to-speech on Google Docs and some of the benefits you can gain from this.

Table of Contents

How to Get Text to Speech on Google Docs

• Go to Google Docs and Open your document.
• Select the portion of text that you want to convert to speech. For the entire document, you can use the keyboard shortcut Ctrl + A for Windows or  Cmd + A  for Mac to select all the text.
• At the top of the Google Docs window, Go to Tools >   Accessibility .
• In the “ Accessibility ” pane that appears on the right side of the document, check the box for “ Turn on screen reader support. ” then click OK.
• Once enabled, you will see a new menu in the toolbar called “ Accessibility .” If you click it, it will open more options.
• Go to Verbalize to Screen reader   >   Verbalize selection .

How To Use Text-To-Speech In Google Docs

There are a couple of ways you can use text-to-speech on Google Docs. In this article, we’ll show you 3 methods:

• Using the inbuilt text-to-speech tool in Google Docs
• Using a text to speech Add-on
• Using a text-to-speech Chrome extension

Let’s look at the steps for each of the methods below.

Method 1: Use the Built-In Text to Speech Google Docs Tool

Google Docs has an inbuilt text-to-speech tool that you can find in the accessibility window. However, before you can use this tool, you need to install the Screen reader  in Chrome. Keep in mind that this extension only works in Chrome. If you’re working on a different browser, you might need to find another extension.

However, you won’t need to install this extension if you already have a screen reader software built-in, like Apple VoiceOver or ChromeVox.

Here’s how to do text-to-speech on Google Docs:

• To have Google Docs read your text aloud, go to Accessibility > Verbalize to screen reader . Then click Verbalize Selection .

The accessibility menu gives you a lot more options. For example, rather than verbalizing the text, you can select the text and have it verbalize the format of the text.

You can also choose to verbalize things like the location of the cursor, the word count, comments, and more.

The tool also helps you keep track of changes  with show live edits as well as keeping track of things like graphics, links, and tables.

That’s it! The selected text will now be read aloud using the text-to-speech feature in Google Docs.

Method 2: Using a Text-to-Speech Add-On

There are plenty of useful add-ons in the Google marketplace, and you can find a couple of text-to-speech add-ons in there as well.

One good add-on we recommend is the Rhetoro text-to-speech add-on.

To install the add-on:

• Go to Extensions >   Add-ons .
• Click Get Add-on .

• Search for rhetoric in the Google Workspace Marketplace window.

• Click on it and click Install .

• Allow permissions by signing in to your Google Account.

Once you’ve finished these steps, the add-on should appear in the extensions menu.

• Go to Extension. The Rhetero add-on should be on the menu.
• Hover on the add-on and click Start Rhetero .

• The Rhetero window will open on the right of Google Docs.

• Select the text you want to convert to speech, then click Generate .
• Your audio will appear under the setting, and you can click play to hear it.

• You can also choose the voice you want to use, the speed for the audio, and the pitch.

The Rhetero add-on is a pretty convenient text-to-speech add-on since it also lets you download the audios it generates, not to mention it’s free to use. You can create a folder  for the downloaded audio and use them for other purposes.

However, if you are visually impaired, you might need some help setting it up.

Method 3: Using a Text-to-Speech Chrome Extension

You can also use Chrome extensions to convert text to speech in Google Docs. Some examples of such extensions include Natural Reader and Read Aloud.

To install the extension:

• Go to Natural Reader
• Click Add to Chrome .

• Click Add extension  in the prompt that appears.

•  Go to the extensions icon on Chrome and pin the Natural reader extension.

• Click on the N icon. A small prompt will appear

• Click the play icon to start the text to speech conversion.

With the Natural reader extension. You also have the option to change the voice and the speed at which the AI reads the text.

This extension also comes with different accents that come with different voices in case you have trouble with the standard English accent. This includes French, Chinese, Japanese, Korean, and many more.

Keep in mind that this extension won’t work if you’re working on Google Docs offline.

Voice-to-Text Google Docs

You can also do voice-to-text in Google Docs by using voice typing. This will allow you to write text in your document without having to type.

How to do voice-to-text in Google Docs:

• Go to Tools
• Choose voice typing

• Click on the red microphone and click Allow.

• Start dictating the text.

The voice-to-text tool works best with earphones or a headset on.

Benefits of Text-to-Speech

Google Docs Text-to-speech technology has several benefits, including the following.

• Text-to-speech allows users with visual impairments or reading difficulties to access the text document. This is very helpful for users with visually difficult or learning disabilities or those with conditions like dyslexia to consume information more effectively.
• With Text to speech, you can text while performing other tasks, which helps you when multitasking. This removes the need for visual focus, allowing you to go through the document in Google Docs while doing other things like commuting or household chores.
• Text-to-speech is a very useful tool if you’re interested in learning a new language or are already doing so. It helps by providing accurate pronunciation and intonation models. It’s also a good way to practice listening comprehension.
• This functionality makes it easier to proofread your work. It’s easier to identify errors if you hear them being read out loud rather than reading the document to find them.
• Text-to-speech can assist you in correctly pronouncing unfamiliar words, proper nouns, or technical terms.
• Text-to-speech can enhance comprehension since it makes it easier to understand, particularly for complex or long texts.
• Text-to-speech can be beneficial for people who experience eye strain or fatigue from reading for a long time.
• Text-to-speech lets you adapt content to different formats, such as audiobooks, podcasts, or spoken presentations. This makes it easier for content creators to reach a broader audience and provides alternative options for content consumption.

Frequently Asked Questions

Can google docs read out loud.

You may be wondering does Google Docs have text-to-speech. The answer is yes. You can enable the text-to-speech option in Google Docs to have the selected text, or the entire document read aloud to you.

It’s a convenient tool for accessing and consuming written content in an auditory format. We’ve shown exactly how to get text-to-speech on Google Docs.

How do I turn off text to speech in Google Docs?

You already know how to turn on text to speech on Google Docs, so here’s how to turn it off:

• At the top of the Google Docs window, go to Tools > Accessibility .
• In the “Accessibility” pane that appears on the right side of the document, uncheck the box next to “ Turn on screen reader support. “
• Once you uncheck the box, click OK . The text-to-speech feature will be disabled, and the document will no longer be read aloud.

Final Thoughts

Text-to-speech can come in handy if you want to make your Google Docs more accessible and convenient to use.

In this text to speech Google Docs tutorial, we’ve shown you how to text to speech on Google Docs in 3 ways. If you found this tutorial useful, check out the related content below or our premium templates, but remember to use the code SSP to save 50%.

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How to Make Google Docs Read to You: A Step-by-Step Guide

Google Docs can read your documents out loud for you, making it easier to absorb information or multitask. You just need to use the built-in text-to-speech feature. Let’s get started!

Step by Step Tutorial on How to Make Google Docs Read to You

Before we dive into the steps, it’s important to note that this feature can help with proofreading, learning a new language, or just for listening to your document as you rest your eyes.

Step 1: Open your Google Doc

Open the Google Docs document you want to be read to you.

Opening your document is the first step. Make sure you’re logged into your Google account and navigate to the Google Docs home page. From there, select the document you wish to have read aloud.

Step 2: Click on “Tools” in the menu bar

In the top menu of Google Docs, click on “Tools”.

The “Tools” menu is located between “Insert” and “Add-ons” on the top menu. This is where you’ll find the option to activate the text-to-speech feature.

Step 3: Select “Accessibility settings”

From the dropdown menu, choose “Accessibility settings”.

In the “Accessibility settings” menu, you’ll find options that make Google Docs more user-friendly for people with different abilities.

Step 4: Click on “Turn on Screen Reader Support”

You should tick the box next to “Turn on Screen Reader Support”.

By enabling this option, you’ll activate the Google Docs text-to-speech function. A message may pop up confirming that you’ve turned on screen reader support.

Step 5: Use the Speak command

Go back to the “Tools” menu, hover over “Accessibility” and then click on “Speak”.

After you’ve turned on screen reader support, the “Speak” option will be available under the “Accessibility” menu. This is the feature that will read your document out loud.

Step 6: Choose what you want to be read aloud

Select “Speak selection” to read the highlighted text or “Speak from the cursor location” to read from a specific point in the document.

Highlight the text you want to be read aloud and choose “Speak selection”, or place the cursor where you want the reading to begin and select “Speak from cursor location”.

After completing these steps, Google Docs will start reading your document out loud. You can pause or stop the reading at any time by going back to the “Tools” menu and clicking on “Accessibility” to find the pause or stop options.

Tips for Making Google Docs Read to You

• Ensure that your device’s volume is turned up so you can hear the reading.
• Use headphones for better sound quality and to avoid disturbing others.
• Customize the voice and speed of reading in your device’s text-to-speech settings for a personalized experience.
• Use the “Speak from the cursor location” option to start reading from a specific point in the document.
• Remember to turn off Screen Reader Support when you’re done, especially if you share the computer with others who might not need this feature.

Frequently Asked Questions

Can google docs read to me in different languages.

Yes, Google Docs can read to you in different languages, but you need to configure your device’s text-to-speech settings to the desired language.

Is the text-to-speech feature available on mobile devices?

Yes, the text-to-speech feature is available on the Google Docs app for mobile devices.

Can I adjust the reading speed?

Yes, you can adjust the reading speed in your device’s text-to-speech settings.

Is this feature free to use?

Yes, Google Docs’ text-to-speech feature is completely free to use.

Can I use this feature offline?

No, you need an internet connection to use Google Docs’ text-to-speech feature because it relies on cloud-based processing.

• Open your Google Docs document.
• Click on “Tools” in the menu bar.
• Select “Accessibility settings”.
• Click on “Turn on Screen Reader Support”.
• Use the Speak command from the “Tools” menu.
• Choose “Speak selection” or “Speak from cursor location”.

In today’s fast-paced world, having tools that can help you multitask and improve efficiency is a game-changer. And when it comes to Google Docs, the ability to have your documents read to you is one of those game-changing features. Whether you’re proofreading, learning, or simply want to rest your eyes, the text-to-speech capability of Google Docs is there to make your life a bit easier. Remember, technology is meant to work for you, and with this feature, you’re able to harness the power of Google Docs to its fullest. So, why not give it a try and see how it can improve your workflow? After all, sometimes, it’s just nicer to listen.

Matthew Burleigh has been writing tech tutorials since 2008. His writing has appeared on dozens of different websites and been read over 50 million times.

After receiving his Bachelor’s and Master’s degrees in Computer Science he spent several years working in IT management for small businesses. However, he now works full time writing content online and creating websites.

His main writing topics include iPhones, Microsoft Office, Google Apps, Android, and Photoshop, but he has also written about many other tech topics as well.

Read his full bio here.

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• Cloud Speech-to-Text
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Transcribe audio from a video file using Speech-to-Text

This tutorial shows how to transcribe the audio track from a video file using Speech-to-Text.

Audio files can come from many different sources. Audio data can come from a phone (like voicemail) or the soundtrack included in a video file.

Speech-to-Text can use one of several machine learning models to transcribe your audio file, to best match the original source of the audio. You can get better results from your speech transcription by specifying the source of the original audio. This allows Speech-to-Text to process your audio files using a machine learning model trained for data similar to your audio file.

In this document, you use the following billable components of Google Cloud:

• Speech-to-Text

To generate a cost estimate based on your projected usage, use the pricing calculator . New Google Cloud users might be eligible for a free trial .

Before you begin

This tutorial has several prerequisites:

• You've set up a Speech-to-Text project in the Google Cloud console.
• You've set up your environment using Application Default Credentials in the Google Cloud console.
• You have set up the development environment for your chosen programming language.
• You've installed the Google Cloud Client Library for your chosen programming language.

Prepare the audio data

Before you can transcribe audio from a video, you must extract the data from the video file. After you've extracted the audio data, you must store it in a Cloud Storage bucket or convert it to base64-encoding.

Extract the audio data

You can use any file conversion tool that handles audio and video files, such as FFmpeg .

Use the code snippet below to convert a video file to an audio file using ffmpeg .

Store or convert the audio data

You can transcribe an audio file stored on your local machine or in a Cloud Storage bucket .

Use the following command to upload your audio file to an existing Cloud Storage bucket using the gsutil tool .

If you use a local file and plan to send a request using the curl tool from the command line, you must convert the audio file to base64-encoded data first.

Use the following command to convert an audio file to a text file.

Send a transcription request

Use the following code to send a transcription request to Speech-to-Text.

Local file request

Refer to the speech:recognize API endpoint for complete details.

To perform synchronous speech recognition, make a POST request and provide the appropriate request body. The following shows an example of a POST request using curl . The example uses the Google Cloud CLI to generate an access token. For instructions on installing the gcloud CLI, see the quickstart .

See the RecognitionConfig reference documentation for more information on configuring the request body.

If the request is successful, the server returns a 200 OK HTTP status code and the response in JSON format:

To learn how to install and use the client library for Speech-to-Text, see Speech-to-Text client libraries . For more information, see the Speech-to-Text Go API reference documentation .

To authenticate to Speech-to-Text, set up Application Default Credentials. For more information, see Set up authentication for a local development environment .

To learn how to install and use the client library for Speech-to-Text, see Speech-to-Text client libraries . For more information, see the Speech-to-Text Java API reference documentation .

To learn how to install and use the client library for Speech-to-Text, see Speech-to-Text client libraries . For more information, see the Speech-to-Text Node.js API reference documentation .

To learn how to install and use the client library for Speech-to-Text, see Speech-to-Text client libraries . For more information, see the Speech-to-Text Python API reference documentation .

Additional languages

C# : Please follow the C# setup instructions on the client libraries page and then visit the Speech-to-Text reference documentation for .NET.

PHP : Please follow the PHP setup instructions on the client libraries page and then visit the Speech-to-Text reference documentation for PHP.

Ruby : Please follow the Ruby setup instructions on the client libraries page and then visit the Speech-to-Text reference documentation for Ruby.

Remote file request

To avoid incurring charges to your Google Cloud account for the resources used in this tutorial, either delete the project that contains the resources, or keep the project and delete the individual resources.

Delete the project

The easiest way to eliminate billing is to delete the project that you created for the tutorial.

Go to Manage resources

• In the project list, select the project that you want to delete, and then click Delete .
• In the dialog, type the project ID, and then click Shut down to delete the project.

Delete instances

Go to VM instances

• Select the checkbox for the instance that you want to delete.
• To delete the instance, click more_vert More actions , click Delete , and then follow the instructions.

Delete firewall rules for the default network

Go to Firewall

• Select the checkbox for the firewall rule that you want to delete.
• To delete the firewall rule, click delete Delete .

What's next

• Learn how to get timestamps for audio.
• Identify different speakers in an audio file.

Try it for yourself

If you're new to Google Cloud, create an account to evaluate how Speech-to-Text performs in real-world scenarios. New customers also get $300 in free credits to run, test, and deploy workloads.

Except as otherwise noted, the content of this page is licensed under the Creative Commons Attribution 4.0 License , and code samples are licensed under the Apache 2.0 License . For details, see the Google Developers Site Policies . Java is a registered trademark of Oracle and/or its affiliates.

Last updated 2024-05-13 UTC.

An Essential Guide to using Text to Speech on Google Docs

Google Docs is perhaps the most indispensable writing tool available to writers today. It is a great collaborative tool that enables multiple individuals to work on the same document in real time from a browser window. It is also constructive because when several people work on the same piece of writing, it enhances the article's essence.

Be it a speech or a feature article, good writing is necessary and Google Docs takes you one step in the right direction.

Serving as a great alternative to MS Word, Google Docs also allows users to auto-save documents, edit and alter the font of the text, include images and tables, change the page orientation, and track modifications, among other things. One of the major differences, however, is that Google Docs is completely online and is accessible from any device. Google Docs is built on Google Drive and, hence, the data is automatically saved on cloud.

Table of Contents

Create the best version of your content, accessibility, multitasking, proofreading and editing, reducing eye strain, chromevox extension, text to speech chrome extension, how to do text to speech on google docs.

If you are a writer, you know that listening to written text helps give a fresh perspective. What looks fine on text might not always sound impressive. This is where Google Docs text to speech feature comes into play.

The text to speech feature in Google Docs allows users to hear what's written, enabling them to make necessary modifications, if necessary, to enhance the quality of the written content. The feature also comes in handy for someone who is multitasking and wants to hear their article or speech one last time before presenting it to an audience.

With this screen reader support, Google Docs has established itself as a best friend for writers and editors. Writers can rest their eyes while Google Docs screen reader feature reads the article for them and helps find flaws or gaps in the writing.

What’s more? Google’s TTS feature is available as an extension and can be downloaded from Google Chrome web browser.

Also read : A Beginner's Guide to WordPress Text to Speech Plugins 

Benefits of Using Text to Speech on Google Docs

TTS on Google Docs unlocks a multitude of benefits, especially for online businesses seeking to enhance accessibility, improve productivity, and cater to diverse audiences.

Text to speech improves the accessibility of written content. If, for instance, you are a teacher teaching visually impaired students, you can convert written material on Google Docs into an accessible audio format. This ensures that every piece of information is readily available to visually impaired students, creating an inclusive learning environment for everyone.

If you are a busy professional juggling multiple tasks at once and preparing for an important presentation, text to speech on Google Docs can help. Your script or notes can be on Google Docs, but you also need to create slides for the presentation . While you focus on creating visually engaging slides, text to speech can read out your script or notes from Google Docs. This makes multitasking easy and boosts productivity.

When you spend hours working on a document, it’s easy to overlook small errors or awkward phrasing. You may also get too familiar with your own writing to spot errors. For example, if you’ve written a research paper, you can use text to speech to listen to it. You might find that some sentences are too long, some phrases are repeated too often, or some words are misused. You might not notice these issues while reading, especially if you’re already familiar with the text.

In the digital age, we spend a significant amount of time looking at screens, which can lead to eye strain. Text to speech is a great tool to alleviate such stress, allowing users to rest their eyes.

Primary Ways to Utilize Google Docs Text to Speech Feature

While there are a number of ways to get Google Docs to read your text aloud, two of the most widely used approaches are the ChromeVox extension and the text to speech extension.

While Google Docs does have built-in text to speech functionality, it’s still dependent on the browser to read all the text out loud. Here are the steps one needs to follow to enable audio in Goggle Docs' text editor.

Step 1: Download the ChromeVox extension on your Google Chrome browser.

Step 2: Open your Google Docs, click on ‘Tools’ in the top menu bar and select the ‘accessibility settings' option.

Sep 3: Enable ‘Turn on Screen Reader Support,’ turn on collaborator announcements and click ‘OK.’

Step 4: Select all the texts in your document or just a portion of the text you want to read aloud. 

Step 5: Go to the new Accessibility menu on your toolbar and highlight the ‘Speak’ option. Then click on the first option called ‘Speak Selection.’ You can also choose to make Google Docs read aloud from your cursor location.

The ChromeVox extension will now read the text aloud using its screen reader option. However, one must be mindful to have only one document open at a time. If multiple Google Docs are open, the extension will start reading each one of them. 

If you don't want a dedicated screen reader software, there are several third-party text to speech tools available in the market, like Capti Voice and Natural Reader , that can help you easily find spots in your Google Docs that need refining or rephrasing by reading the select text out loud. These TTS tools are easy to use and can be utilized on any computer or laptop alike, and work on every web page. 

The TTS feature on Google Docs can be accessed in several ways. The primary way, if you already use a screen reader software such as ChromeVox on your computer, is:

Step 1: Turn on screen reader support

Open Google Docs and open a file. In the tools menu, select 'Accessibility settings' and select 'Turn on screen reader' support.

Step 2: Check your screen reader settings

Depending on the screen reader being used, adjust your settings to add any additional setup if needed.

Step 3: Start listening

Open the Google Doc that you want read aloud, select the text, tap on accessibility, and then the 'Speak' option and choose 'Speak Selection.' 

In three simple steps, you can now listen to the text out loud. 

Also read : How realistic is text to speech?

How can Murf's TTS be an Alternative to Google Docs TTS Voiceover?

When it comes to text to speech extensions for Google Docs, Murf AI stands out as a superior choice for several reasons:

Enhanced Voice Quality: Murf is renowned for its exceptional voice quality. The AI-powered voices produced by Murf sound more natural, human-like, and expressive compared to the generic text to speech voices offered by Google Docs. This higher level of voice quality enhances the overall listening experience, making the content more engaging and professional.

Audio Customizations: Murf's powerful audio editing features set it apart from other text to speech extensions. Users can alter the volume levels to provide the best clarity, highlight particular words or phrases, change the pitch to create various moods, and adjust the pitch. With the help of these editing tools, users may give their voiceovers a unique flair, enhancing their impact and dynamism.

Downloadable TTS Files: Murf surpasses Google Docs' constraints by allowing users to download the text to speech files that are produced. For individuals who need to access the audio offline or incorporate it into other platforms and programs, this function is helpful. Users now have more freedom and control over the content generated, thanks to Murf.

Multi-Language Support: Murf excels in supporting a wide range of languages, allowing users to create content in different languages. Moreover, users can select different accents of the same language for better personalization, for example, text to speech British accent , text to speech Indian English, Cantonese Chinese , and much more.

To sum up, Murf AI surpasses other Google Doc text to speech extensions available due to its extensive customization options, downloadable TTS files, superior voice quality, advanced audio editing capabilities, and comprehensive language support. These features make Murf a powerful and versatile tool for creating high-quality reading and listening experiences.

Why Should I Opt for Google TTS? 

Today, Google Docs not just helps improve one's efficiency but its text to speech feature enables people with visual impairments or learning disabilities to retain information in a better manner, enabling them to accomplish their goals seamlessly. All in all, you deserve the best, and so does your writing. So, go ahead and explore Google Docs TTS feature to transform the quality of your content! 

Can Google Docs read out loud?

Yes, Google Docs can be read out loud with Chrome extensions such as ChromeVox. 

What is the shortcut for text to speech on Google Docs?

Select the text you want to read and press Ctrl+Shift+S. A window with a microphone icon will appear; click on it when you're ready to dictate.

How do I enable text to speech in Google Docs?

Follow these steps to enable text to speech in Google Docs:

Enable “Screen Reader Support” in the “Accessibility settings” under the “Tools” menu in Google Docs.

Install screen reader plugins like “Speechify Text to Speech Voice Reader” or “NaturalReader” to read the text aloud.

Once enabled, a new menu called “Accessibility” will appear on the toolbar. From there, select the text you want to hear, and then use the “Speak” command under the “Accessibility” menu.

Can I use text to speech on Google Docs for free?

Yes, Google Docs has a free text to talk feature, but requires support from screen reader plugins on your browser. These plugins are often free to use, but may impose some restrictions on the voices or languages available or the duration of the voiceover.

What languages are supported by text to speech on Google Docs?

Google text to speech feature supports a wide range of languages and accents, such as English, Chinese, Spanish, French, German, Italian, and more, depending on the screen reader tool you use. The plugin you install should list the supported languages. 

Is there a limit on the length of text for TTS on Google Docs?

There are no limits on the length of text imposed by Google Docs. Limits, if any, will depend on the screen reader support or text to speech tool you use, especially if using a free version.

Can I use text to speech for editing and proofreading in Google Docs?

The text to speech feature in Google Docs is particularly useful when editing or proofreading. Having the document read out loud can help you spot grammatical errors, long, awkward sentences, and repeated phrases that you may miss during visual reading. This facilitates a better and more economical editing procedure.

Does TTS work with images and non-text elements in Google Docs?

No, at this point, the TTS function incorporated in Google Docs does not support translating images and non-text elements. Some third-party text to speech applications or web apps can provide this function.

Can I customize the voice or accent in text to speech on Google Docs?

Most speech readers and text to speech tools provide a range of voices and various accents, according to your preference. Use their plugin interface to choose a voice and accent that best resonates with you.

Can I use text to speech Google Docs in multiple languages within the same document?

Yes, you can use the text to speech feature in Google Docs with multiple languages within the same document. Just ensure you select the right voices and languages from your screen reader support plugin UI for the said selection.

You should also read:

An in-depth guide on how to use Text to Speech on Discord

Medical Text to Speech: Changing Healthcare for the Better

Making A Difference for the Dyslexic with Text to Speech

Simple, Useful Tricks on Google Products

2 Ways To Use Text-To-Speech in Google Docs to Read Aloud Text

For a few months now, I have been using text-to-speech in Google Docs to read aloud my documents so I could make them sound more natural. You probably don’t know that Google Docs comes with dedicated text-to-speech options to allow your screen reader app to read aloud Google Docs documents.

If you are missing out on this awesome Google Docs feature, I’ve got you covered. In this post, I’ll show you how to use the Google Docs text-to-speech feature to read aloud documents. Additionally, I will also share a nifty third-party text-to-speech tool that is definitely worth checking out if you don’t want to use a desktop screen reader.

1. Use Google Docs Screen Reader to read text aloud

Before you use Google Docs screen reader options, you need to get a dedicated screen reader software that will read aloud the text in a Google Docs document. You don’t need to go through this step if you already have a screen reader software built-in, like Apple VoiceOver or ChromeVox . If not, then I will recommend you use the NVDA screen reader software.

It’s a free open-source screen reader software that is small in size and very easy to use. There are no special settings to configure to use it with Google Docs. Just download and install the software and follow the below instructions to use it with Google Docs.

If you don’t want to use desktop screen reader software, then you can also use this Screen Reader Chrome extension by Google. This screen reader will only work inside the Chrome browser rather than your whole operating system. It also doesn’t require any special setting configuration to work with Google Docs.

Enable Google Docs Screen Reader

Your screen reader software will not be able to read the text inside a Google Docs document if the Google Docs screen reader option isn’t enabled. Here’s how to enable screen reader in Google Docs:

Click on the “Tools” menu in the top bar and select “Accessibility settings” in it.

Now check the checkbox next to “Turn on screen reader support” and click on “OK” .

Use text-to-speech in Google Docs

After following the above instructions, you will notice a new Accessibility menu in the top bar; you can use it to read aloud text in Google Docs. If you still can’t find the Accessibility option, then press the Ctrl+Alt+Z keys on your keyboard.

1. Open up the document and select the text you want to read aloud (press Ctrl+A to select all the text).

2. Now click on  “Accessibility”  in the top menu bar and select  “Speak selection”  in the  “Speak” option. Your screen reader software will read aloud the text.

There is also a  Google Docs keyboard shortcut  for this purpose. Once the required text is selected, press  Ctrl+Alt+X  keys to start reading aloud.

Note: Some screen reader software can directly read aloud text just by highlighting, so you may not need to go through the above process depending on your screen reader software.

2. Use a text-to-speech Chrome extension

You can also use a text-to-speech Chrome extension for Google Docs if you don’t want to use a dedicated screen reader software. A text-to-speech extension will copy the Google Docs content in its own interface and then read it aloud. For this purpose, I really like the Read Aloud  Chrome extension. It’s astonishingly easy to use, yet it’s very powerful.

The extension works on almost every web page, including web apps like Google Docs. Just open up the document, and click on the extension button to start reading the text aloud. You also don’t need to select the text, Read Aloud will automatically recognize text that should be read aloud.

If you go to its settings, you can select voice type, volume, pitch, and speed. Best of all, Read Aloud can read the text in over 40 different languages. There is a good chance your particular language is supported.

If Read Aloud doesn’t work well for you, then you can use the Speak It Chrome extension as an alternative. This extension also works very similarly, but it also lets you directly highlight text in your browser to read aloud.

Note: You don’t need to enable the screen reader option in Google Docs to use these text-to-speech Chrome extensions.

Wrapping up

If you are blind or vision impaired, then you should definitely use your screen reader software with Google Docs by enabling screen reader support in Google Docs. However, if you just want to quickly read aloud your Google Docs document, then using a text-to-speech extension is much better. Do let us know in the comments how you’ll be using text-to-speech in Google Docs.

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Karrar Haider

For over 10 years, Karrar has been writing about everything Google and Windows with a strict focus on improving security and finding ways to get more out of our devices.

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21 Responses

• Comments 21
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Doesn’t work on a mobile device, I guess

thank you for sharing

There is no “Accessibility” in the top menu bar, even after I enabled screen reading.

Press Ctrl+Alt+Z keys to show “Accessibility” in the top menu bar.

Read Allowed is fabulous! Good to have another option when Google Docs Screen Reader just doesn’t work. Thanks

I am trying to allow for my special needs students to hear a text read to them. I have done all of the above on my Google Doc, but when I select the text and then select accessibility/speak/speak selection (or press ctrl+alt+x) it does not read aloud from my Chromebook, or with headphones. Thank you for any assistance you can provide.

Same here..and yes, volume for everything else is high and working :(

im having the same issue :(

Can’t get it working. Found all of the steps easily, but it isn’t reading. I’m using it on a macbook, so maybe there is a separate step that’s needed?

Yeah I did all the above. Not working at all. Guess google isn’t a big fan of accessibility

Doesn’t work

Unfortunately this does not work on Google Pixel mobile device.

I have turned on Accessibility Selected the document that I need reading clicked on Speak and Speak selection

Looks like there may be one more small thing that I have not done.

Please advice

Read Aloud extension works like a charm. Woohoo

I was using this in MS word for emails and everywhere. I caught my silly mistakes very easily. I missed this simple feature in google docs. I must say this article is not easy to find.

Thank you very much. Providing the link to the Chrome Add-on is extremely useful.

Please keep us posted if Accessibility feature starts working.

I originally thought this extension didn’t work because it didn’t show up in Docs extensions – it’s for Chrome, so, my error.

it does not work i have tried the things that you suggested for me to try

Why did you post lies? Nothing works on anyones device!

Y is it not working on literally anyone’s device? I’ve followed all the steps and still doesn’t work pretty much everyone is having troubles.

I have the same issue as everyone else and have tried everything. This did not help at all and I’ve been trying for months

IT DID NOT HELP DO NOT TRY!!!

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Read Aloud: A Text to Speech Voice Reader

Read aloud the current web-page article with one click, using text to speech (TTS). Supports 40+ languages.

Read Aloud uses text-to-speech (TTS) technology to convert webpage text to audio. It works on a variety of websites, including news sites, blogs, fan fiction, publications, textbooks, school and class websites, and online university course materials. Read Aloud allows you to select from a variety of text-to-speech voices, including those provided natively by the browser, as well as by text-to-speech cloud service providers such as Google Wavenet, Amazon Polly, IBM Watson, and Microsoft. Some of the cloud-based voices may require additional in-app purchase to enable. Read Aloud can read PDF, Google Docs, Google Play books, Amazon Kindle, and EPUB (via the excellent EPUBReader extension from epubread.com). Read Aloud is intended for users who prefer to listen to content instead of reading, those with dyslexia or other learning disabilities, and children learning to read. To use Read Aloud, navigate to the web page you want to read, then click the Read Aloud icon on the Chrome menu. In addition, the shortcut keys ALT-P, ALT-O, ALT-Comma, and ALT-Period can be used to Play/Pause, Stop, Rewind, and Forward. You may also select the text you want to read before activating the extension. Right clicking on the selected text will provide you with yet another option to activate Read Aloud via the context menu. To change the voice, reading speed, pitch, or enable text highlighting, go to the Options page either by right clicking on the Read Aloud icon and choose Options, or by clicking the Gear button on the extension popup (you'll need to stop playback to see the Gear button). Read Aloud is an open-source project. If you wish to contribute bug fixes or translations, please visit the GitHub page at https://github.com/ken107/read-aloud.

4.2 out of 5 3K ratings Google doesn't verify reviews. Learn more about results and reviews.

Pablo Vault May 15, 2024

These voices are outdated and annoying asf

huhi2 May 15, 2024

why does the text to speech text highlight only works on popup or in a seperate window ? why not make it work inside the window ? and it could highlight the text inside the windows while also scroll down while it reads the window page, like an inline text highlighting would be great

Read Aloud: A Text to Speech Voice Reader handles the following:

This developer declares that your data is.

• Not being sold to third parties, outside of the approved use cases
• Not being used or transferred for purposes that are unrelated to the item's core functionality
• Not being used or transferred to determine creditworthiness or for lending purposes

Pericles: Text to Speech Screen Reader

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Speechify Text to Speech Voice Reader

Read aloud any Google Doc, PDF, webpage, or book with text to speech (TTS). Natural sounding voices in 30+ languages & 130 voices.

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Select the text and let Talking Web read it for you.

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The 7 Best Text-to-Speech Chrome Extensions

Text-to-speech programs can be an incredibly vital tool for many. If you're looking for one, here are the seven best text-to-speech Chrome extensions.

Text-to-speech programs can come in very handy, whether you need to use the extension for reading difficulties, or just because you like having text read aloud. Chrome extensions are the perfect format to use these programs as you browse the web.

So, here we’ve listed some of the best text-to-speech extensions for Chrome.

1. Natural Reader

An intelligent extension, Natural Reader works great for almost any type of text, including PDF, Google Docs, eBooks, and emails.

Natural Reader also has an immersive reader mode that lets you read without any distractions. For those with dyslexia, the immersive reader mode supports dyslexic fonts to make reading easier.

To instruct Natural Reader to start reading, you can use the hotkey Alt + R . Alternatively, if you want to listen to only a part of the text, simply select the text and click on the Natural Reader icon at the end of the selected text.

From the extension settings, you can adjust voice and speed, listen to uploaded PDFs, save to mobile, and set hotkeys.

Natural Readers supports 20 languages, including English, Spanish, French, and German. Other than the Chrome extension, Natural Reader has web, iOS, and Android apps.

Though the extension is free to use, you can get more voice options with Premium and Pro plans, starting from $10 per month.

Download: Natural Reader for Chrome (Free, Paid)

2. Speechify

Speechify is one of the most powerful text-to-speech Chrome extensions on the list.

After downloading the extension, you'll view a floating widget on the right side of your screen. When you click on the play button , the extension starts reading from the beginning of the page. You can, however, enable Click to Listen and start listening from any particular point on the webpage.

It supports 30 different languages and 130 voices. Besides the usual webpages and blogs, Speechify can read out scanned texts, PDFs, and even tweets for you on the Twitter web app.

Speechify lets you save webpages to the library for listening to at a later time. The Premium plan costs $11.58 per month (billed annually) and offers additional voices and languages, lets you listen to scanned texts, and supports importing, highlighting, and skipping.

Perhaps the most useful feature of the paid plan is the ability to increase audio speed. Speechify's mobile app is one of the most popular text-to-speech apps for Android as well as iOS. So, whether you're a student, struggle with reading, or prefer listening to articles, Speechify can come in really handy.

Download: Speechify for Chrome (Free, Paid)

3. Read Aloud

Read Aloud is an open-source project that is specially designed for people who prefer listening to content rather than reading it. It offers support for 40 languages.

Read Aloud can read different formats like Google Docs, blog posts, PDFs, Amazon Kindle, Google Play Books, etc. To listen to any piece of text, select and right-click it, then choose Read aloud selected text . Alternatively, you can use the shortcut Alt + P .

It lets you adjust the reading speed, volume, and pitch from the Settings icon. Moreover, you can choose whether to highlight the played text.

Read Aloud has around a million downloads on Chrome Web Store, so it’s definitely a popular TTS extension for Chrome.

Download: Read Aloud for Chrome (Free)

4. Snap&Read

Snap&Read is a feature-rich reading extension that lets you listen to any kind of text. Other than webpages, Google Docs, and PDFs, Snap&Read can also read text from images and scanned documents using OCR.

To listen to any text, select the Loud Speaker icon from the sidebar, then click on the text from where you want Snap&Read to read.

For listening to text from screenshots or images, select the Rectangular Selection icon . Select the area from where you want Snap&Read to detect and read text.

Moreover, Snap&Read can translate the text into other languages and adjust the readability of the text. Using this extension, you can remove distractions and change the spacing and number of words per line to create a better reading experience.

Snap&Read is a great text-to-speech extension, especially for educators and students. It costs $3.99 per month, but you can access a free trial.

Download: Snap&Read for Chrome ($3.99 per month)

5. Talkie: Text to Speech

Talkie is a simple text-to-speech Chrome extension that supports multiple languages. As it is quite a basic extension, Talkie is a good choice if you need limited features.

To make Talkie read any text, select the text, right-click it, and choose Talkie from the context menu. Talkie automatically detects the languages, selects a voice, and reads the text for you. For setting a default voice, you’ll have to upgrade to Premium.

It doesn't have any word limits and can work offline if the languages are downloaded. Best of all, you can download more TTS languages and voices for your operating system, and Talkie can auto-detect and use them.

Most of the features are free, but you can also upgrade to Premium for more options. Talkie Premium does not have a fixed price, but is a pay-what-you-want subscription.

Download : Talkie: Text to Speech for Chrome (Free, Paid)

6. Intelligent Speaker

Whether you want to listen to articles, PDFs, Google Docs, or uploaded text, Intelligent Speaker got you covered.

This extension supports 20 languages and automatically detects the language. You can read complete web pages as well as selected text. To make the voice sound more natural, you can turn on breathing.

Available as a browser add-on, Intelligent Speaker lets you sync your content to a podcast app, so you can listen to articles on the go. You can even download the converted audio file using this extension. Intelligent Speaker works offline and is available for all major browsers.

The free plan supports only one hour of listening each month, so you'll have to subscribe to Premium, which costs $6.99 per month, for unlimited listening.

Download: Intelligent Speaker for Chrome (Free, Paid)

7. Text to Speech

Text to Speech Chrome extension by Hewzio is a simple yet useful extension. It can read the entire web page for you, supporting 30 languages.

To listen to any article, simply click on the extension icon or right-click the screen and choose Read Page . The extension will start reading the page from the beginning. To listen to selected text, play the audio and click on the sentence from where you want it to read.

Text to Speech also has a distraction-free reader mode, making it one of the extensions that enhance your reading experience . You can sync articles across devices, including mobile phones, and create podcasts from articles using Text to Speech by Hewzio.

The free plan does the basic job of converting text into audio, but the paid plans offer more features, including the dark mode. There are three paid plans, ranging from $1 to $10 per month.

Download: Text to Speech for Chrome (Free, Paid)

Let the Extension Read Out the Screen for You

Whether you want to read webpages, documents, or images, these Chrome extensions can read out the screen for you. These extensions are a great way for students to learn different languages and avoid reading long research papers.

Similarly, these text-to-speech extensions are really useful for people with vision impairment or reading difficulties like dyslexia.

Text to speech Afrikaans

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Table of contents, south african afrikaans text to speech (tts), the history of afrikaans, text to speech south african afrikaans accents (tts south african afrikaans), google translate, other tts: speechify, conclusion: tts is a useful resource.

TTS readers with text to speech Afrikaans support can enhance your understanding of the South African language in audio form. Here's how.

To a non-speaker, South African Afrikaans isn’t the most straightforward language to understand or learn. However, the right technology can quickly change things. Even native speakers may have trouble advancing their language knowledge or have difficulty with certain pronunciations and dialects. Sometimes turning text into audio is the best way to overcome such obstacles.

TTS, or  text to speech  technology, converts written text from web pages, documents, PDFs , HTML files, and even pictures into audio in the form of AI speech. Text to speech is a popular assistive technology in the educational space. TTS offers numerous benefits in leisure activities and can help users with dyslexia , ADHD , and other reading difficulties improve their language comprehension skills. So, why use TTS with South African Afrikaans? As a native Afrikaans speaker, you can use it for the same reason everyone else does—to make your life easier by becoming a multitasking and productivity master by eliminating your need to read. As a non-Afrikaans speaker, you can use TTS software to translate and spell words in Afrikaans to further your understanding of the language and improve your communication skills.

Although Afrikaans is mainly a South African language, its use crosses outside the South African borders. The language sees plenty of use throughout the Africa by many different people. Afrikaans’ roots as a creole language go back to the 19th century. The language evolved during the colonialism period in South Africa and has many language influences, including:

Unlike the English language, South African Afrikaans doesn’t have nearly as many accents and dialects. Many speakers identify three primary dialects.

• Cape Afrikaans—This dialect has stronger Portuguese influences.
• Orange River Afrikaans—This dialect features more Khoi language influences.
• East Cape Afrikaans—This dialect has predominant Dutch and English influences.

Due to the diverse background of the South African Afrikaans language, the dialects are often mutually intelligible. Locals rarely have trouble understanding each other, even when using slightly different dialects and accents. At the same time, this makes using text to speech technology trickier to turn written text into speech. Powerful machine learning algorithms are necessary for proper Afrikaans text to speech conversions in real-time. However, that doesn’t mean high-quality, natural-sounding voices aren’t available for South African TTS speech engine users.

How to generate text to speech in South African Afrikaans accent

There are a few ways to get authentic narrations for text to speech audio in South African Afrikaans.

The Google Voice Generator feature from Google Translate is available for free. It uses Natural Neural Network Technology to power its translator feature and the text to speech engine. How does it work? It’s as easy as opening the Google Translate service in your browser and typing something in the text box. You can write up to 5,000 characters per individual translation. The best part about using this Google service is the automatic translation. You can write your text in English, and Google Translate will convert it into Afrikaans. From there, you can press the speaker button to hear the audio version of the text. Naturally, some translations are hit and miss. You’ll notice that some conversions have a reviewed icon marking them as accurate, while others don’t. While Google Translate is a quick way to get a text to speech South African Afrikaans translation you can use for personal and commercial purposes, the biggest downside is the very unnatural, robotic voice that doesn’t differentiate between the three main dialects. You also have to either type or copy and paste the text you want to hear into the translate box every time.

Suppose you want a more professional service . Play.ht does a better job generating Afrikaans accents than Google Translate. Play.ht is a TTS service with three South African Afrikaans voices, one male and two female. The standard voices use computer-generated algorithms. The text to speech voices use machine learning speech synthesis to produce relatively natural-sounding voices in real-time. The speech recognition capabilities of the premium service are superior to what Google or Microsoft can do now. Of course, play.ht supports other languages like Turkish, Swedish, Filipino, Spanish, Italian, etc.

If you want to explore your options with text to speech technology, Speechify is an excellent choice. At the moment, the platform doesn’t support Afrikaans. However, Speechify is always adding new languages as soon as the speech synthesis process is sufficiently optimized for the task. What sets Speechify apart from other TTS apps are its very natural-sounding voices, its versatility across many devices and operating systems, and simply how easy it is to use. Language learners, people with reading difficulties, or anyone who simply enjoys listening to audio content instead of reading it can all benefit from Speechify. Currently, you can try Speechify for other similarly complex languages with different characteristics than the English language. Here are some of your choices:

• And many more

These languages have TTS support but also allow translations, making learning easier for users. The Speechify API is available on multiple platforms, including Android , iOS , Microsoft Windows (via the Chrome extension ), and others. You can listen to narrations in real-time or download the conversions in an MP3 or WAV audio file format.

Using a TTS reader, with or without a translation feature, can significantly impact how you manage daily activities and workflow issues. Reading is still a great way to absorb information, but not everyone reads as quickly as others. Conditions like dyslexia, ADHD , visual impairments, and other conditions can make it difficult to read fluently and process complex sentences. Text to speech software can create an environment where users may follow the text at a comfortable speed while hearing the correct pronunciation. Alternatively, you can boost your productivity by listening to written text faster than the average reading speed. With Speechify, you can turn the playback speed up to nine times faster than usual. A TTS reader offers multiple advantages in many languages, whether for convenience or necessity. Still not convinced? Try Speechify for free , experience premium voice narration, and see how quickly it can improve your online and offline interactions and language understanding.

Lahnda text to speech voices

Alternatives to Podcastle.ai for Podcast Creators

Cliff Weitzman

Cliff Weitzman is a dyslexia advocate and the CEO and founder of Speechify, the #1 text-to-speech app in the world, totaling over 100,000 5-star reviews and ranking first place in the App Store for the News & Magazines category. In 2017, Weitzman was named to the Forbes 30 under 30 list for his work making the internet more accessible to people with learning disabilities. Cliff Weitzman has been featured in EdSurge, Inc., PC Mag, Entrepreneur, Mashable, among other leading outlets.

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USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 1 of 70 IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT TIKTOK INC., and BYTEDANCE LTD., V. ) Petitioners, No. 24-1113 MERRICK B. GARLAND, in his official capacity as Attorney General of the United States, (Page 1 of Total) Respondent. PETITION FOR REVIEW OF CONSTITUTIONALITY OF THE PROTECTING AMERICANS FROM FOREIGN ADVERSARY CONTROLLED APPLICATIONS ACT

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 2 of 70 2. That law 1. Congress has taken the unprecedented step of expressly singling out and banning TikTok: a vibrant online forum for protected speech and expression used by 170 million Americans to create, share, and view videos over the Internet. For the first time in history, Congress has enacted a law that subjects a single, named speech platform to a permanent, nationwide ban, and bars every American from participating in a unique online community with more than 1 billion people worldwide. the Protecting Americans From Foreign Adversary Controlled Applications Act (the "Act") is unconstitutional. Banning Tik Tok is so obviously unconstitutional, in fact, that even the Act's sponsors recognized that reality, and therefore have tried mightily to depict the law not as a ban at all, but merely a regulation of TikTok's ownership. According to its sponsors, the Act responds to TikTok's ultimate ownership by ByteDance Ltd., a company with Chinese subsidiaries whose employees support various Byte Dance businesses, including TikTok. They claim that the Act is not a ban because it offers Byte Dance a choice: divest TikTok's U.S. business or be shut down.1 ― - 1 References to "TikTok Inc." are to the specific U.S. corporate entity that is a Petitioner in this lawsuit and publishes the TikTok platform in the 1 (Page 2 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 3 of 70 3. But in reality, there is no choice. The "qualified divestiture" demanded by the Act to allow TikTok to continue operating in the United States is simply not possible: not commercially, not technologically, not legally. And certainly not on the 270-day timeline required by the Act. Petitioners have repeatedly explained this to the U.S. government, and sponsors of the Act were aware that divestment is not possible. There is no question: the Act will force a shutdown of TikTok by January 19, 2025, silencing the 170 million Americans who use the platform to communicate in ways that cannot be replicated elsewhere. 4. Of course, even if a "qualified divestiture" were feasible, the Act would still be an extraordinary and unconstitutional assertion of power. If upheld, it would allow the government to decide that a company may no longer own and publish the innovative and unique speech United States. References to "TikTok" are to the online platform, which includes both the Tik Tok mobile application and web browser experience. References to “ByteDance Ltd." are to the specific Cayman Islands- incorporated holding company that is identified in the Act and is a Petitioner in this lawsuit. References to "ByteDance" are to the ByteDance group, inclusive of ByteDance Ltd. and relevant operating subsidiaries. TikTok Inc. and ByteDance. Ltd. are together referred to as "Petitioners." (Page 3 of Total) 21

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 4 of 70 platform it created. If Congress can do this, it can circumvent the First. Amendment by invoking national security and ordering the publisher of any individual newspaper or website to sell to avoid being shut down. And for Tik Tok, any such divestiture would disconnect Americans from the rest of the global community on a platform devoted to shared content an outcome fundamentally at odds with the Constitution's commitment to both free speech and individual liberty. 5. There are good reasons why Congress has never before enacted a law like this. Consistent with the First Amendment's guarantee of freedom of expression, the United States has long championed a free and open Internet - and the Supreme Court has repeatedly recognized that speech "conveyed over the Internet” fully qualifies for “the First Amendment's protections." 303 Creative LLC v. Elenis, 600 U.S. 570, 587 (2023). And consistent with the fundamental principles of fairness and equal treatment rooted in the Bill of Attainder Clause and the Fifth Amendment, Congress has never before crafted a two-tiered speech regime with one set of rules for one named platform, and another set of rules for everyone else. (Page 4 of Total) 3

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 5 of 70 6. In dramatic contrast with past enactments that sought to regulate constitutionally protected activity, Congress enacted these extreme measures without a single legislative finding. The Act does not articulate any threat posed by Tik Tok nor explain why TikTok should be excluded from evaluation under the standards Congress concurrently imposed on every other platform. Even the statements by individual Members of Congress and a congressional committee report merely indicate concern about the hypothetical possibility that TikTok could be misused in the future, without citing specific evidence - even though the platform has operated prominently in the United States since it was first launched in 2017. Those speculative concerns fall far short of what is required when First Amendment rights are at stake. 7. Nor is there any indication that Congress considered any number of less restrictive alternatives, such as those that Petitioners developed with the Executive Branch after government agencies began evaluating the security of U.S. user data and the risk of foreign government influence over the platform's content as far back as 2019. While such concerns were never substantiated, Petitioners nevertheless (Page 5 of Total) 4

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 6 of 70 worked with the government for four years on a voluntary basis to develop a framework to address the government's concerns. 8. As part of this engagement, Petitioners have voluntarily invested more than $2 billion to build a system of technological and governance protections sometimes referred to as "Project Texas" - to help safeguard U.S. user data and the integrity of the U.S. TikTok platform against foreign government influence. Petitioners have also made extraordinary, additional commitments in a 90-page draft National Security Agreement developed through negotiations with the Committee on Foreign Investment in the United States ("CFIUS”), including agreeing to a “shut-down option” that would give the government the authority to suspend TikTok in the United States if Petitioners violate certain obligations under the agreement. 9. Congress tossed this tailored agreement aside, in favor of the politically expedient and punitive approach of targeting for disfavor one publisher and speaker (TikTok Inc.), one speech forum (TikTok), and that forum's ultimate owner (ByteDance Ltd.). Through the Act's two-tiered. structure, Congress consciously eschewed responsible industry-wide. regulation and betrayed its punitive and discriminatory purpose. 5 (Page 6 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 7 of 70 Congress provided every other company however serious a threat to - national security it might pose - paths to avoiding a ban, excluding only Tik Tok Inc. and ByteDance Ltd. Indeed, for any other company's application to be banned, Congress mandated notice and a "public report" describing "the specific national security" concern, accompanied by supporting classified evidence. For Petitioners only, however, there is no statement of reasons and no supporting evidence, with any discussion of the justifications for a ban occurring only behind closed doors. 10. Congress must abide by the dictates of the Constitution even when it claims to be protecting against national security risks: “against [those] dangers ... as against others, the principle of the right to free speech is always the same." Abrams v. United States, 250 U.S. 616, 628 (1919) (Holmes, J., dissenting). Congress failed to do so here, and the Act should be enjoined. 11. Jurisdictional Statement Pursuant to Sections 3(a) and 3(b) of the Act, H.R. 815, div. H, 118th Cong., Pub. L. No. 118-50 (April 24, 2024), this Court has original (Page 7 of Total) 6

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 8 of 70 and exclusive jurisdiction over this challenge to the constitutionality of the Act. 2 A. 12. Background and Nature of Proceedings TikTok Is a Speech Platform Used by 170 Million Americans. Tik Tok is an online video entertainment platform designed to provide a creative and entertaining forum for users to express themselves and make connections with others over the Internet. More than 170 million Americans use TikTok every month, to learn about and share information on a range of topics from entertainment, to religion, to - politics. Content creators use the TikTok platform to express their opinions, discuss their political views, support their preferred political candidates, and speak out on today's many pressing issues, all to a global audience of more than 1 billion users. Many creators also use the 2 A copy of the Act is attached to this Petition as Exhibit A. Because this Petition does not involve a challenge to any agency action, it is not governed by Federal Rule of Appellate Procedure 15(a). Petitioners intend to file a separate motion regarding the procedures governing this original proceeding. Petitioners summarize the pertinent facts and claims below to facilitate this Court's review consistent with the practice of a case-initiating pleading in a court of original jurisdiction, but reserve their rights to present additional facts and arguments in due course. 7 (Page 8 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 9 of 70 platform to post product reviews, business reviews, and travel information and reviews. 13. In the United States, the TikTok platform is provided by Tik Tok Inc., a California-incorporated company that has its principal place of business in Culver City, California and offices in New York, San Jose, Chicago, and Miami, among other locations. TikTok Inc. has thousands of employees in the United States. Like many platforms owned by companies that operate globally, the global TikTok platform is supported not only by those employees, but also by employees of other ByteDance subsidiaries around the globe, including in Singapore, the United Kingdom, Brazil, Germany, South Africa, Australia, and China. Many of the global TikTok platform's functions are spread across different corporate entities and countries, and the global TikTok business is led by a leadership team based in Singapore and the United States. Like other U.S. companies, TikTok Inc. is governed by U.S. law. 14. Tik Tok Inc.'s ultimate parent company is ByteDance Ltd., a Cayman Islands-incorporated equity holding company. Byte Dance was founded in 2012 by Chinese entrepreneurs. Over time, the company sought funding to fuel growth, as is common in the technology sector, 8 (Page 9 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 10 of 70 which resulted in the issuance of additional equity and the dilution of existing shares. Today, approximately 58 percent of ByteDance Ltd. is owned by global institutional investors (such as BlackRock, General Atlantic, and Susquehanna International Group), 21 percent is owned by the company's founder (a Chinese national who lives in Singapore), and 21 percent is owned by employees including approximately 7,000 Americans. 15. ByteDance launched TikTok in May 2017 in over 150 countries, including the United States.³ Since its launch, TikTok has become one of the world's most popular applications, with over 1 billion users worldwide. As of January 2024, more than 170 million Americans use TikTok on a monthly basis. 16. Users primarily view content on TikTok through its "For You" page, which presents a collection of videos curated by TikTok's proprietary recommendation engine. The recommendation engine customizes each user's content feed based on how the user interacts with 3 Tik Tok was later relaunched in August 2018 following a transaction involving the company Musical.ly. See generally Petition for Review, Tik Tok Inc. v. CFIUS, No. 20-1444 (D.C. Cir. Nov. 10, 2020). 9 (Page 10 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 11 of 70 the content that the user watches. TikTok's popularity is based in large part on the effectiveness of the recommendation engine. The source code for TikTok's recommendation engine was originally developed by ByteDance engineers based in China, and the engine is customized for operations in TikTok's various global markets, including in the United States. TikTok is not offered in mainland China. 17. Aside from TikTok, ByteDance has developed and operates more than a dozen other online platforms and software applications for use in U.S. and international markets, including for content-sharing, video and music editing, e-commerce, gaming, and enterprise productivity. B. 18. The Government Previously Made Unlawful Attempts to Ban TikTok. Petitioners' efforts to address the U.S. government's asserted concerns regarding the TikTok platform date back to 2019. At that time, Petitioners began engaging with CFIUS, which had initiated a review of ByteDance Ltd.'s 2017 acquisition of Musical.ly, another Internet-based video-sharing platform. (Page 11 of Total) 10

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 12 of 70 19. Petitioners were in the early stages of engaging with CFIUS on a voluntary basis to address the government's concerns, when on August 6, 2020, President Trump abruptly issued an executive order purporting to ban TikTok under the International Emergency Economic Powers Act ("IEEPA”), 50 U.S.C. §§ 1701-08. See 85 Fed. Reg. 48,637 (the "Ban Order"). Two separate district courts preliminarily enjoined the Ban Order, concluding (among other things) that it exceeded the President's IEEPA authority. TikTok Inc. v. Trump, 490 F. Supp. 3d 73, 83 (D.D.C. 2020); TikTok Inc. v. Trump, 507 F. Supp. 3d 92, 112 (D.D.C. 2020); Marland v. Trump, 498 F. Supp. 3d 624, 641 (E.D. Pa. 2020). 20. Specifically, as these courts correctly recognized, the President's IEEPA authority "to deal with any unusual and extraordinary threat" to the nation “does not include the authority to regulate or prohibit, directly or indirectly ... [any] personal communication” or the importation or exportation “of any information or informational materials.” 50 U.S.C. § 1702(b)(1), (3). These restrictions on the President's IEEPA authority-which Congress expanded through multiple amendments to the statute were designed “to prevent the statute from running afoul of the First Amendment.” United States v. 11 (Page 12 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 13 of 70 Amirnazmi, 645 F.3d 564, 585 (3d Cir. 2011) (quotation marks omitted); see also Kalantari v. NITV, Inc., 352 F.3d 1202, 1205 (9th Cir. 2003) (IEEPA's limitations necessary “to prevent the executive branch from restricting the international flow of materials protected by the First. Amendment"); Marland, 498 F. Supp. 3d at 629 (same). 21. Looking to the foundational First Amendment principles codified in IEEPA's text and legislative history, these courts concluded that President Trump's efforts to ban TikTok violated the statute and raised "serious" constitutional questions (which were unnecessary to decide under the doctrine of constitutional avoidance). Tik Tok Inc., 507 F. Supp. 3d at 112 n.6; TikTok Inc., 490 F. Supp. 3d at 83 n.3. The courts granted the government's motions to voluntarily dismiss its appeals after President Biden withdrew the Ban Order. See Tik Tok Inc. v. Biden, No. 20-5302, 2021 WL 3713550 (D.C. Cir. July 20, 2021); Tik Tok Inc. v. Biden, No. 20-5381, 2021 WL 3082803 (D.C. Cir. July 14, 2021); Marland v. Trump, No. 20-3322, 2021 WL 5346749 (3d Cir. July 14, 2021). 22. Separately, acting on a CFIUS referral, President Trump on August 14, 2020 issued an order under Section 721 of the Defense Production Act, 50 U.S.C. § 4565, purporting to direct ByteDance to 12 (Page 13 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 14 of 70 divest from TikTok's U.S. business and U.S. user data. 85 Fed. Reg. 51,297 (the "Divestment Order"). On November 10, 2020, Petitioners petitioned this Court for review of the Divestment Order and underlying CFIUS actions, arguing, among other things, that the government lacked jurisdiction under the statute. See Petition for Review, TikTok Inc. v. CFIUS, No. 20-1444 (D.C. Cir. Nov. 10, 2020). That petition was held in abeyance in February 2021 on the parties' joint motion to allow the parties to negotiate a resolution. The government has filed status reports every 60 days since then, most recently on April 22, 2024. Those status reports have consistently reported that “[t]he parties continue to be involved in ongoing negotiations” and “[a] beyance continues to be appropriate.” See, e.g., Status Report, Tik Tok Inc. v. CFIUS, No. 20-1444 (D.C. Cir. Apr. 22, 2024). 23. Between January 2021 and August 2022, Petitioners and CFIUS engaged in an intensive, fact-based process to develop a National Security Agreement that would resolve the U.S. government's concerns about whether Chinese authorities might be able to access U.S. user data or manipulate content on TikTok, as well as resolve the pending CFIUS During that time, Petitioners and government officials dispute. 13 (Page 14 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 15 of 70 communicated regularly, often several times a week - including several - in-person meetings about the government's concerns and potential solutions. The result was an approximately 90-page draft National Security Agreement with detailed annexes embodying a comprehensive solution addressing the government's national security concerns. Notably, the draft National Security Agreement provided that all protected U.S. user data (as defined in the agreement) would be stored in the cloud environment of a U.S.-government-approved partner, Oracle Corporation, which would also review and vet the TikTok source code. 24. From Petitioners' perspective, all indications were that they were nearing a final agreement. After August 2022, however, CFIUS without explanation stopped engaging with Petitioners in meaningful discussions about the National Security Agreement. Petitioners repeatedly asked why discussions had ended and how they might be restarted, but they did not receive a substantive response. In March 2023, without providing any justification for why the draft National Security Agreement was inadequate, CFIUS insisted that Byte Dance would be required to divest the U.S. TikTok business. (Page 15 of Total) 14

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 16 of 70 25. Since March 2023, Petitioners have explained to CFIUS, in multiple written communications and in-person meetings, that a divestiture of the U.S. TikTok business from the rest of the integrated global Tik Tok platform and business of the sort now required by the Act is not feasible. CFIUS has never articulated any basis for disagreeing with that assessment, offering instead only a conclusory assertion that the reason ByteDance was not divesting was because it was simply unwilling to do so. The Act nonetheless incorporates precisely such an infeasible divestiture standard. C. 26. A Divestiture that Severs TikTok's U.S. Operations From the Rest of the Globally Integrated TikTok Business Is Not Commercially, Technologically, or Legally Feasible. The Act purports to allow Petitioners to avoid a ban by executing a "qualified divestiture." Sec. 2(c). But that alternative is illusory because, as Petitioners have repeatedly explained to CFIUS, the divestiture of the TikTok U.S. business and its severance from the globally integrated platform of which it is an integral part is not commercially, technologically, or legally feasible. (Page 16 of Total) 15

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 17 of 70 - 27. First, a standalone U.S. TikTok platform would not be commercially viable. TikTok and its competitors are globally integrated platforms where content created in one country is available to users in other countries. Indeed, a substantial part of TikTok's appeal is the richness of the international content available on the platform from global sporting events like the Olympics to international K-pop stars from South Korea, as well as videos created by U.S. creators and enjoyed by audiences worldwide. A divestment of the U.S. TikTok platform, without any operational relationship with the remainder of the global platform, would preclude the interoperability necessary to make international content seamlessly available in the U.S. market and vice versa. As a result, the U.S. TikTok platform would become an “island” where Americans would have an experience detached from the rest of the global platform and its over 1 billion users. Such a limited pool of content, in turn, would dramatically undermine the value and viability of the U.S. TikTok business.4 4 The contemplated qualified divestiture would also undercut the important role currently played by American voices in the global conversation ongoing on TikTok. 16 (Page 17 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 18 of 70 28. Second, precipitously moving all TikTok source code development from ByteDance to a new Tik Tok owner would be impossible as a technological matter. The platform consists of millions of lines of software code that have been painstakingly developed by thousands of engineers over multiple years. Although much of this code is basic infrastructure for running the global TikTok platform and has nothing at all to do with TikTok's recommendation algorithm, the statute requires that all of this code be wrested from Petitioners, so that there is no “operational relationship" between ByteDance and the new U.S. platform. Specifically, to comply with the law's divestiture requirement, that code base would have to be moved to a large, alternative team of engineers a team that does not exist and would have no understanding of the complex code necessary to run the platform. It would take years for an entirely new set of engineers to gain sufficient familiarity with the source code to perform the ongoing, necessary maintenance and development activities for the platform. Moreover, to keep the platform functioning, these engineers would need access to ByteDance software tools, which the Act prohibits. Such a fundamental rearchitecting is not - (Page 18 of Total) 17

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 19 of 70 remotely feasible on anything approaching the 270-day timeframe contemplated by the Act. 29. Third, the Chinese government has made clear that it would not permit a divestment of the recommendation engine that is a key to the success of TikTok in the United States. Like the United States,5 China regulates the export of certain technologies originating there. China's export control rules cover “information processing technologies” such as "personal interactive data algorithms.”6 China's official news agency has reported that under these rules, any sale of recommendation algorithms developed by engineers employed by ByteDance subsidiaries in China, including for TikTok, would require a government license. 5 For example, the U.S. Department of Commerce has issued restrictions on the export to China of advanced chips that can be used to train artificial intelligence models. E.g., Implementation of Additional Export Controls: Certain Advanced Computing Items; Supercomputer and Semiconductor End Use; Updates and Corrections, 88 Fed. Reg. 73458 (Oct. 25, 2023) (to be codified at 15 C.F.R. § 732.2 et seq.). 6 See Karen M. Sutter, Cong. Rsch. Serv., IN11524, China Issues New Export Control Law and Related Policies 2 (2020). 7 Paul Mozur, Raymond Zhong & David McCabe, Tik Tok Deal Is Complicated by New Rules From China Over Tech Exports, N.Y. Times (Aug. 29, 2020), https://perma.cc/L6RB-CTT9. 18 (Page 19 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 20 of 70 China also enacted an additional export control law that "gives the Chinese government new policy tools and justifications to deny and impose terms on foreign commercial transactions."8 China adopted these enhanced export control restrictions between August and October 2020, shortly after President Trump's August 6, 2020 and August 14, 2020 executive orders targeting TikTok. By doing so, the Chinese government clearly signaled that it would assert its export control powers with respect to any attempt to sever TikTok's operations from ByteDance, and that any severance would leave TikTok without access to the recommendation engine that has created a unique style and community that cannot be replicated on any other platform today. D. 30. The Act Bans TikTok and Other Byte Dance Applications. On April 24, 2024, the President signed the Protecting Americans from Foreign Adversary Controlled Applications Act. 31. The Act prohibits, on pain of draconian penalties, “online mobile application store[s]" and "internet hosting services" from servicing "foreign adversary controlled application[s]" within the United States. 8 Sutter, supra n.6. 19 (Page 20 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 21 of 70 See Sec. 2(a), 2(d)(1)(A). This includes the "distribution, maintenance, or updating" of a covered application through an online marketplace. Sec. 2(a)(1). 32. Section 2(g) (3) creates two classes of "foreign adversary controlled applications" covered by the Act. 33. The first class singles out only one corporate group: "Byte Dance[] Ltd.,” “TikTok,” their “subsidiar[ies] or successor[s]" that are "controlled by a foreign adversary," or any entity "owned or controlled" by the aforementioned.9 The Act deems any application. operated by these entities a “foreign adversary controlled application," without any finding about why any particular application much less - - every application operated by these entities should be so designated. See Sec. 2(g)(3)(A). 9 “TikTok” is a platform, not a legal entity. Petitioners assume that Congress intended this provision to be a reference to TikTok Inc., and further reserve their rights to amend this Petition to include additional Tik Tok entities to the extent the government takes the position that other entities are covered by this reference. In any event, TikTok Inc. is covered as an entity “owned or controlled" by ByteDance Ltd. 20 (Page 21 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 22 of 70 34. The second class creates a discretionary process by which the President can designate other companies whose applications will also effectively be banned. Under these provisions, the President may designate an application as a "foreign adversary controlled application" if several qualifications are met: a. Covered Company. The website or application is operated directly or indirectly by a "covered company" - i.e., a company that operates a website or application that permits users to share content and has at least 1 million monthly active users. See Sec. 2(g)(2)(A). b. Controlled by a Foreign Adversary. The "covered company" operating the website or application must also be "controlled by a foreign adversary," meaning it is "headquartered in, has its principal place of business in, or is organized under the laws" of a "foreign adversary country," which currently includes China, North Korea, Russia, and Iran. Sec. 2(g)(1)(A), (g)(4); see also 10 U.S.C. § 4872(d)(2). A company may also be "controlled by a foreign adversary" if persons domiciled in any of the 21 (Page 22 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 23 of 70 (Page 23 of Total) specified countries (i.e., China, Iran, Russia, or North Korea) directly or indirectly own at least 20 percent of the company. Sec. 2(g)(1)(B). c. Not Exempt under Sec. 2(g)(2)(B). But Congress specifically exempted from the term “covered company" any "entity that operates" a website or application "whose primary purpose is to allow users to post product reviews, business reviews, or travel information and reviews." An entity that operates a single website or application of this nature thus cannot be a “covered company,” even if it is "controlled by a foreign adversary," poses a significant national security risk, and separately operates an application whose primary purpose is anything other than allowing users to post reviews. Sec. 2(g)(2)(B). d. Presidential Determination, Notice and Report, and Judicial Review. Finally, the President must determine that such a company presents “a significant threat to the national security of the United States." Sec. 2(g)(3)(B)(ii). Before making such a determination, the President must 22

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 24 of 70 issue public notice proposing the determination and then provide a public report to Congress describing "the specific national security concern involved," supplemented by a classified annex, and also explain "what assets would need to be divested to execute a qualified divestiture." Id. These presidential determinations are then subject to judicial review. Sec. 3(a). 35. Section 2(c) exempts a "foreign adversary controlled application[]" from the Act's prohibitions if the company that operates the application executes a “qualified divestiture." Sec. 2(c). The President must determine that such divestiture would (1) "result in the relevant covered company no longer being controlled by a foreign adversary," and (2) “preclude[] the establishment or maintenance of any operational relationship" between the application's U.S. operations and any formerly affiliated entities that are controlled by a foreign adversary, including "any cooperation with respect to the operation of a content. recommendation algorithm." Sec. 2(c), (g) (6). As noted above, the Act's broad definition of "controlled by a foreign adversary" includes, among other things, any entity organized under the laws of a "foreign adversary 23 (Page 24 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 25 of 70 country," or any entity in which a foreign person domiciled in a foreign adversary country holds at least a 20 percent ownership stake. Sec. 2(g)(1), (3)(B)(i), (4). 36. The prohibition on providing Internet hosting and mobile application store services to TikTok and other ByteDance applications. takes effect 270 days after enactment. Sec. 2(a)(2)(A). The President may extend this deadline, but only for 90 days maximum, and only if the President certifies to Congress that a path to executing a qualified divestiture has been identified, evidence of significant progress toward executing that qualified divestiture has been produced, and the relevant binding legal agreements to enable execution of the qualified divestiture are in place. 37. "Before the date on which [this] prohibition" takes effect, Petitioners are required to provide, upon request by any U.S. user of any of their applications, “all the available data related to the account of such user with respect to such application." Sec. 2(b).10 10 Because Section 2(b)'s data portability requirement applies "[b]efore" the prohibition under Section 2(a) takes effect, it cannot be "given effect" without Section 2(a) for purposes of Section 2(e)(1) of the Act, which provides that "[i]f any provision of this section or the application of this 24 (Page 25 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 26 of 70 38. Because the Act lacks any legislative findings or a statement of purpose, Petitioners and the more than 170 million American monthly users of TikTok are left to scrutinize statements from individual Members of Congress and other sources to try to discern any purported justification for this extraordinary intrusion on free speech rights. Based on these sources, it appears at least some Members of Congress sought to address "two threats" that could emerge from foreign ownership of communications platforms. 11 39. First, they may have sought to protect U.S. users' “data security."12 According to the House Committee Report for an earlier version of the Act, mobile applications, including those that are not section to any person or circumstance is held invalid, the invalidity shall not affect the other provisions or applications of this section that can be given effect without the invalid provision or application." Because Section 2(a) violates the Constitution for the reasons set forth herein, Section 2(b) is accordingly "not operative in the absence of the unconstitutional provision.” Barr v. Am. Ass'n of Pol. Consultants, Inc., 140 S. Ct. 2335, 2352 n.9 (2020). 11 Jane Coaston, What the Tik Tok Bill Is Really About, According to a Leading Republican, N.Y. Times (Apr. 1, 2024), https://perma.cc/BL32- 786X (quoting the Act's original sponsor, Rep. Mike Gallagher). 12 Id. (Page 26 of Total) 25

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 27 of 70 controlled by foreign adversaries, can “collect vast amounts of data on Americans."13 The House Committee Report expressed a concern that such data could be used by a foreign adversary to "conduct espionage campaigns," such as by tracking specific individuals. 14 40. Second, others in Congress appear to have been motivated by a "greater concern": an alleged "propaganda threat." 15 One proponent of the Act stated that communications applications could be used to "push misinformation, disinformation, and propaganda on the American public."16 Another supporter claimed in the House Select Committee press release accompanying the bill's introduction that “[TikTok] is ... poisoning the minds of our youth every day on a massive scale."17 13 H.R. Comm. on Energy & Com., Protecting Americans from Foreign Adversary Controlled Applications Act, H.R. Rep. No. 118-417 at 2 (2024) (hereinafter the "House Committee Report"). 14 Id. 15 Coaston, supra n.11 (quoting Rep. Gallagher). 16 House Committee Report at 2. 17 Press Release, U.S. House Select Comm. on Strategic Competition Between the U.S. and the Chinese Communist Party, Gallagher, Bipartisan Coalition Introduce Legislation to Protect Americans From Foreign Adversary Controlled Applications, Including TikTok (Mar. 5, 2024), https://perma.cc/KC5T-6AX3. (Page 27 of Total) 26

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 28 of 70 E. Congress Disregarded Alternatives to Banning TikTok, Such as the National Security Measures Petitioners Negotiated with the Executive Branch. 41. Petitioners have demonstrated a commitment to addressing both of those concerns without the need to resort to the drastic, unconstitutional step of shuttering one of the most widely used forums for speech in the United States. The 90-page draft National Security Agreement that Petitioners developed with Petitioners developed with CFIUS would, if implemented, provide U.S. TikTok users with protections more robust than those employed by any other widely used online platform in the industry. 42. The draft National Security Agreement contains several means of ensuring data security without banning TikTok. All protected U.S. user data (as defined in the National Security Agreement) would be safeguarded in the United States under a special corporate structure: TikTok U.S. Data Security (a new subsidiary of Tik Tok Inc.). A special board, with Security Directors whose appointment would be subject to the U.S. government's approval, would oversee TikTok U.S. Data Security, and in turn exclude ByteDance and all of its other subsidiaries and affiliates from such responsibilities. Further separation between the 27 (Page 28 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 29 of 70 U.S. TikTok business and Byte Dance subsidiaries and affiliates, including TikTok in the rest of the world, would be achieved by appointing a U.S.-government-approved Security Director to the board of Tik Tok Inc. Protected U.S. user data would be stored in the cloud environment of a U.S.-government-approved partner, Oracle Corporation, with access to such data managed by TikTok U.S. Data Security. 43. The draft Agreement would also protect against the concern about content manipulation and propaganda. Multiple layers of protection address concerns related to content available on the TikTok platform, including ensuring that all content moderation - both human and algorithmic ➖ would be subject to third-party verification and monitoring. The concern about content manipulation would also be addressed by securing all software code through Oracle Corporation, a U.S. trusted technology provider. The Tik Tok U.S. platform and application would be deployed through the Oracle cloud infrastructure and subject to source code review and vetting by Oracle with another U.S.-government-approved third party responsible for conducting security inspections. As part of this process, Oracle and third parties 28 (Page 29 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 30 of 70 approved by CFIUS would conduct independent inspections of the Tik Tok recommendation engine. 44. The draft Agreement also includes strict penalties for noncompliance, including a "shut-down option," giving the government the authority to suspend TikTok in the United States in response to specified acts of noncompliance. The Agreement also provides significant monetary penalties and other remedies for noncompliance. 45. Although the government has apparently abandoned the draft National Security Agreement, Petitioners have not. TikTok Inc. has begun the process of voluntarily implementing the National Security Agreement's provisions to the extent it can do so without the U.S. government's cooperation, including by incorporating and staffing the TikTok U.S. Data Security entity, and by partnering with Oracle Corporation on the migration of the U.S. platform and protected U.S. user data to Oracle's cloud environment. 46. To date, Petitioners have spent more than $2 billion to implement these measures and resolve the very concerns publicly expressed by congressional supporters of the Act all without the overbroad and unconstitutional method of an outright ban. 29 (Page 30 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 31 of 70 Grounds On Which Relief Is Sought Petitioners seek review of the constitutionality of the Act on grounds that include, without limitation, the following. Ground 1: Violation of the First Amendment 47. The First Amendment to the U.S. Constitution provides that "Congress shall make no law. . . abridging the freedom of speech." U.S. Const., amend. I. 48. By banning all online platforms and software applications offered by "TikTok" and all ByteDance subsidiaries, Congress has made a law curtailing massive amounts of protected speech. Unlike broadcast television and radio stations, which require government licenses to operate because they use the public airwaves, the government cannot, consistent with the First Amendment, dictate the ownership of newspapers, websites, online platforms, and other privately created. speech forums. 49. Indeed, in the past, Congress has recognized the importance of protecting First Amendment rights, even when regulating in the interest of national security. For example, Congress repeatedly amended IEEPA which grants the President broad authority to address national 30 (Page 31 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 32 of 70 emergencies that pose "unusual and extraordinary threat[s]" to the country to expand protections for constitutionally protected materials. 50 U.S.C. §§ 1701-02. Accordingly, under IEEPA, the President does not have the authority to even indirectly regulate "personal communication" or the importation or exportation "of any information or informational materials,” id. § 1702(b)(1), (3) limitations that are necessary "to prevent the statute from running afoul of the First Amendment," Amirnazmi, 645 F.3d at 585. Yet Congress has attempted to sidestep these statutory protections aimed at protecting Americans' constitutional rights, preferring instead to simply enact a new statute that tries to avoid the constitutional limitations on the government's existing statutory Those statutory protections were evidently seen as an impediment to Congress's goal of banning TikTok, so the Act dispensed authority. with them. 50. The Act's alternative to a ban a so-called “qualified - - divestiture" is illusory to the point of being no alternative at all. As explained above, divesting TikTok Inc.'s U.S. business and completely severing it from the globally integrated platform of which it is a part is not commercially, technologically, or legally feasible. 31 (Page 32 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 33 of 70 51. The Act will therefore have the effect of shutting down TikTok in the United States, a popular forum for free speech and expression used by over 170 million Americans each month. And the Act will do so based not on any proof of a compelling interest, but on speculative and analytically flawed concerns about data security and content manipulation concerns that, even if grounded in fact, could be - addressed through far less restrictive and more narrowly tailored means. 52. Petitioners' protected speech rights. The Act burdens Tik Tok Inc.'s First Amendment rights in addition to the free speech - rights of millions of people throughout the United States in two ways. - 53. First, Petitioner TikTok Inc. has a First Amendment interest in its editorial and publishing activities on TikTok. See Hurley v. Irish- Am. Gay, Lesbian & Bisexual Grp. of Bos., 515 U.S. 557, 570 (1995). TikTok “is more than a passive receptacle or conduit for news, comment, and advertising" of others; TikTok Inc.'s "choice of material" to recommend or forbid “constitute[s] the exercise of editorial control and judgment" that is protected by the First Amendment. Miami Herald Pub. Co. v. Tornillo, 418 U.S. 241, 258 (1974); see also Alario v. Knudsen, (Page 33 of Total) 32

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 34 of 70 - F. Supp. 3d, 2023 WL 8270811, at *6 (D. Mont. Nov. 30, 2023) (recognizing Tik Tok Inc.'s First Amendment editorial rights). 54. As the government itself has acknowledged, “[w]hen [social media] platforms decide which third-party content to present and how to present it, they engage in expressive activity protected by the First Amendment because they are creating expressive compilations of speech." Br. for United States as Amicus Curiae at 12-13, Moody v. NetChoice LLC, No. 22-277 (U.S.), 2023 WL 8600432; see also id. at 18- 19, 25-26. 55. Second, Tik Tok Inc. is among the speakers whose expression the Act prohibits. TikTok Inc. uses the TikTok platform to create and share its own content about issues and current events, including, for example, its support for small businesses, Earth Day, and literacy and education. 18 When TikTok Inc. does so, it is engaging in core speech protected by the First Amendment. See Sorrell v. IMS Health Inc., 564 18 Tik Tok (@tiktok), TikTok, https://www.tiktok.com/t/ZTL9QsTYs/ (last visited May 6, 2024); TikTok (@tiktok), TikTok, https://www.tiktok.com/t/ZTL9QbSHv/ (last visited May 6, 2024); TikTok (@tiktok), TikTok, https://www.tiktok.com/t/ZTL9QXE7R/ (last visited May 6, 2024). (Page 34 of Total) 33

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 35 of 70 U.S. 552, 570 (2011); NetChoice, LLC v. Att'y Gen., Fla., 34 F.4th 1196, 1210 (11th Cir. 2022), cert. granted, 144 S. Ct. 478 (2023). The Act precludes TikTok Inc. from expressing itself over that platform. 56. Even if the U.S. TikTok platform could be divested, which it cannot for the reasons explained above, TikTok Inc.'s protected speech rights would still be burdened. Because the Act appears to conclusively determine that any application operated by "TikTok" - a term that — Congress presumably meant to include Tik Tok Inc. is a foreign adversary controlled application, Sec. 2(g)(3)(A), the President appears to lack the power to determine that a TikTok Inc.-owned application is "no longer being controlled by a foreign adversary" and has no “operational relationship" with “formerly affiliated entities that are controlled by a foreign adversary," Sec. 2(g)(6)(A) & (B). The Act therefore appears to conclusively eliminate TikTok Inc.'s ability to speak through its editorial and publishing activities and through its own. account on the TikTok platform. 57. For similar reasons, the Act burdens the First Amendment rights of other ByteDance subsidiaries to reach their U.S. user audiences, (Page 35 of Total) 34

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 36 of 70 since those companies are likewise prohibited from speaking and engaging in editorial activities on other ByteDance applications. 58. The Act is subject to strict scrutiny. The Act's restrictions on Petitioners' First Amendment rights are subject to strict scrutiny for three independent reasons. 59. First, the Act represents a content- and viewpoint-based restriction on protected speech. The Act discriminates on a content basis because it exempts platforms "whose primary purpose" is to host specific types of content: "product reviews, business reviews, or travel information and reviews.” Sec. 2(g)(2)(B). The Act thus “distinguish[es] favored speech" - i.e., speech concerning travel information and business reviews "from disfavored speech" ―i.e., all other types of - speech, including particularly valuable speech like religious and political content. Turner Broad. Sys., Inc. v. FCC, 512 U.S. 622, 643 (1994). 60. The Act also discriminates on a viewpoint basis because it appears to have been enacted at least in part because of concerns over the viewpoints expressed in videos posted on TikTok by users of the platform. For example, the House Committee Report asserted, without supporting evidence, that Tik Tok "can be used by [foreign adversaries] to 35 (Page 36 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 37 of 70 push misinformation, disinformation, and propaganda on the American public" 19 a concern that in any event could be raised about any platform for user-generated content. See infra ¶¶82, 87. Similarly, Rep. Raja Krishnamoorthi, who co-sponsored the Act, expressed the unsubstantiated concern that “the platform continued to show dramatic differences in content relative to other social media platforms."20 61. Second, the Act discriminates between types of speakers. As explained above, TikTok Inc. is a protected First Amendment speaker with respect to the TikTok platform. The Act facially discriminates between Tik Tok Inc. and other speakers depending on the "primary purpose” of the platforms they operate. Any application offered by Petitioners is automatically deemed a “foreign adversary controlled application,” without any exclusions or exceptions. Sec. 2(g)(3)(A). By contrast, any other company's application can be deemed a "foreign adversary controlled application” only if the company does not operate a 19 House Committee Report at 2. 20 Sapna Maheshwari, David McCabe & Annie Karni, House Passes Bill to Force Tik Tok Sale From Chinese Owner or Ban the App, N.Y. Times (Mar. 13, 2024), https://perma.cc/Z7UE-WYH6. (Page 37 of Total) 36

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 38 of 70 website or application "whose primary purpose is to allow users to post product reviews, business reviews, or travel information and reviews." Sec. 2(g)(2)(B). The Act thus favors speakers that do offer such websites or applications over speakers that do not. 62. Moreover, the Act singles out TikTok Inc. and other subsidiaries of ByteDance for unique disfavor in other ways. Whereas other companies with ownership in a country deemed a "foreign adversary" become subject to the Act's restrictions only upon a presidential determination that the company poses "a significant threat to the national security of the United States,” Sec. 2(g)(3)(B), ByteDance Ltd. and its subsidiaries are automatically subject to the Act's draconian restrictions by fiat, Sec. 2(g)(3)(A). The standard and process that the Act specifies for every other company likely fall short of what is required. by the First Amendment and other applicable constitutional protections, but TikTok Inc. and ByteDance have been singled out for a dramatically different, even more clearly unconstitutional regime with no public notice, no process for a presidential determination that there is a significant national security threat, no justification of that determination by a public report and submission of classified evidence to Congress, and 37 - (Page 38 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 39 of 70 no judicial review for statutory and constitutional sufficiency based on the reasons set forth in the presidential determination. The Act also draws a speaker-based distinction insofar as it specifically names Byte Dance Ltd. and TikTok, and also exempts applications with fewer than 1 million monthly users (except if those applications are operated by ByteDance Ltd. or TikTok). Sec. 2(g)(2)(A)(ii), (3)(A). 63. A statutory restriction targeting specific classes of speakers is subject to strict scrutiny. See United States v. Playboy Ent. Grp., Inc., 529 U.S. 803, 812 (2000) ("Laws designed or intended to suppress or restrict the expression of certain speakers contradict basic First Amendment principles."). And that is especially true when, as here, the Act singles out Petitioners by name for uniquely disfavored treatment and congressional statements indicate that the Act targets Petitioners in part because of concerns about the content on TikTok. Because the Act "target[s]" both "speakers and their messages for disfavored treatment,” strict scrutiny review is required. Sorrell, 564 U.S. at 565; see also Turner, 512 U.S. at 658-60. 64. Third, the Act is subject to strict scrutiny as an unlawful prior restraint. The Supreme Court has "consistently" recognized in a "long 38 (Page 39 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 40 of 70 line" of cases that government actions that “deny use of a forum in advance of actual expression" or forbid “the use of public places [for plaintiffs] to say what they wanted to say" are prior restraints. Se. Promotions, Ltd. v. Conrad, 420 U.S. 546, 552-53 (1975). “[P]rior restraints on speech and publication are the most serious and the least. tolerable infringement on First Amendment rights." Nebraska Press Ass'n v. Stuart, 427 U.S. 539, 559 (1976). The Act suppresses speech in advance of its actual expression by prohibiting all U.S. TikTok users including Petitioner Tik Tok Inc. - from communicating on the platform. See Backpage.com, LLC v. Dart, 807 F.3d 229 (7th Cir. 2015) (defendant's conduct restricting the operator of classified advertising website was a prior restraint); Org. for a Better Austin v. Keefe, 402 U.S. 415, 418–19 (1971) (ban on distributing leaflets a prior restraint); U.S. WeChat Users All. v. Trump, 488 F. Supp. 3d 912, 926 (N.D. Cal. 2020) (ban on communications application a prior restraint). The same is true of other Byte Dance subsidiaries and their platforms. Such restrictions “bear[] a heavy presumption against [their] constitutional validity." Se. Promotions, 420 U.S. at 558. (Page 40 of Total) 39

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 41 of 70 65. The Act fails strict scrutiny because it does not further a compelling interest. Strict scrutiny “requires the Government to prove that the restriction [1] furthers a compelling interest and [2] is narrowly tailored to achieve that interest." Reed v. Town of Gilbert, 576 U.S. 155, 171 (2015) (numerical alterations added). "If a less restrictive alternative would serve the Government's purpose, the legislature must use that alternative." Playboy, 529 U.S. at 813. The Act fails on both counts. 66. The Act does not further a compelling interest. To be sure, national security is a compelling interest, but the government must show that the Act furthers that interest. To do so, the government "must do more than simply posit the existence of the disease sought to be cured." Turner, 512 U.S. at 664 (plurality op.). Rather, it “must demonstrate that the recited harms are real, not merely conjectural, and that the regulation will in fact alleviate these harms in a direct and material way." Id. 67. Congress itself has offered nothing to suggest that the TikTok platform poses the types of risks to data security or the spread of foreign propaganda that could conceivably justify the Act. The Act is devoid of 40 (Page 41 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 42 of 70 any legislative findings, much less a demonstration of specific harms that Tik Tok supposedly poses in either respect, even though the platform was first launched in 2017. 68. The statements of congressional committees and individual Members of Congress during the hasty, closed-door legislative process preceding the Act's enactment confirm that there is at most speculation, not "evidence,” as the First Amendment requires. Instead of setting out evidence that TikTok is actually compromising Americans' data security by sharing it with the Chinese government or spreading pro-China propaganda, the House Committee Report for an earlier version of the Act relies repeatedly on speculation that Tik Tok could do those things. See, e.g., House Committee Report at 6 (TikTok could “potentially [be] allowing the CCP 'to track the locations of Federal employees and contractors") (emphasis added) (quoting Exec. Order 13,942, 85 Fed. Reg. 48637, 48637 (Aug. 6, 2020)); id. at 8 (discussing "the possibility that the [CCP] could use [TikTok] to control data collection on millions of users") (emphasis added); id. ("Tik Tok has sophisticated capabilities that create the risk that [it] can ……. suppre[ss] statements and news that the PRC deems negative") (emphasis added). Speculative risk of harm is simply 41 (Page 42 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 43 of 70 not enough when First Amendment values are at stake. These risks are even more speculative given the other ways that the Chinese government could advance these asserted interests using a variety of intelligence tools and commercial methods. See infra 85–87. 69. The conjectural nature of these concerns are further underscored by President Biden's decision to continue to maintain a Tik Tok account for his presidential campaign even after signing the Act into law. 21 Congressional supporters of the Act have also maintained campaign accounts on TikTok. 22 This continued use of TikTok by President Biden and Members of Congress undermines the claim that the platform poses an actual threat to Americans. 70. Further, even if the government could show that TikTok or another ByteDance-owned application "push[es] misinformation, disinformation, and propaganda on the American public," House 21 Monica Alba, Sahil Kapur & Scott Wong, Biden Campaign Plans to Keep Using Tik Tok Through the Election, NBC News (Apr. 24, 2024), https://perma.cc/QPQ5-RVAD. 22 Tom Norton, These US Lawmakers Voted for Tik Tok Ban But Use It Themselves, Newsweek (Apr. 17, 2024), https://perma.cc/AQ5F-N8XQ. At least one Member created a TikTok account after the Act was enacted. See https://perma.cc/L3GT-7529. (Page 43 of Total) 42

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 44 of 70 Committee Report at 2, the government would still lack a compelling interest in preventing Americans from hearing disfavored speech. generated by TikTok users and shared on the platform just because the government considers it to be foreign "propaganda." See Lamont v. Postmaster Gen. of U.S., 381 U.S. 301, 305 (1965). 71. The Act also offers no support for the idea that other applications operated by subsidiaries of ByteDance Ltd. pose national security risks. Indeed, the legislative record contains no meaningful discussion of any ByteDance-owned application other than TikTok― let alone evidence “proving” that those other applications pose such risks. Reed, 576 U.S. at 171. 72. - The Act also provides neither support nor explanation for subjecting Petitioners to statutory disqualification by legislative fiat while providing every other platform, and users of other platforms, with a process that includes a statutory standard for disqualification, notice, a reasoned decision supported by evidence, and judicial review based on those specified reasons. Only Petitioners are subjected to a regime that has no notice and no reasoned decision supported by evidence - opening the door to, among other things, post-hoc arguments that may not have 43 (Page 44 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 45 of 70 been the basis for the government action. The Supreme Court recently explained that the requirement of a "reasoned explanation" is "meant to ensure that [the government] offer[s] genuine justifications for important decisions, reasons that can be scrutinized by courts and the interested public. Accepting contrived reasons would defeat the purpose of the enterprise." Dep't of Com. v. New York, 139 S. Ct. 2551, 2576 (2019). Depriving Petitioners of those protections imposes a dramatically heavier burden on the free speech rights of Petitioners and TikTok users that is wholly unjustified and certainly not supported by a compelling interest. The Act also fails strict scrutiny because it is not narrowly tailored. "Even where questions of allegedly urgent national security. . . are concerned," the government must show that "the evil that would result from the [restricted speech] is both great and certain and cannot be mitigated by less intrusive measures.” CBS, Inc. v. Davis, 510 U.S. 1315, 1317 (1994). To satisfy narrow tailoring, the Act must represent the least restrictive means to further the government's asserted data security and propaganda interests, Sable Commc'ns of Cal., Inc. v. FCC, 492 U.S. 115, 126 (1989), and be neither over- nor under- 73. (Page 45 of Total) 44

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 46 of 70 inclusive, Ark. Writers' Project, Inc. v. Ragland, 481 U.S. 221, 232 (1987). The Act fails in each of these respects. 74. The Act opts for a wholesale prohibition on Petitioners offering online applications in lieu of a multitude of less restrictive measures it could have taken instead. As discussed above, Petitioners have been involved in negotiations with CFIUS since 2019 over a package of measures that would resolve the government's concerns about data security and purported propaganda related to TikTok. The terms of that negotiated package are far less restrictive than an outright ban. The negotiations have resulted in the draft National Security Agreement, which Tik Tok Inc. is already in the process of voluntarily implementing to the extent it can do so without government action. That initiative includes a multi-billion-dollar effort to create a new TikTok U.S. subsidiary devoted to protecting U.S. user data and have U.S.-based Oracle Corporation store protected U.S. TikTok user data in the United States, run the TikTok recommendation system for U.S. users, and inspect TikTok's source code for security vulnerabilities. 75. If executed by the government, the National Security Agreement would also give CFIUS a "shut-down option" to suspend 45 (Page 46 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 47 of 70 Tik Tok in the United States in response to specified acts of noncompliance. The government has never meaningfully explained why the National Security Agreement (a far less restrictive alternative to an outright, total ban) is insufficient to address its stated concerns about data security and propaganda. 76. Even if the government's dissatisfaction with the draft. National Security Agreement were valid (despite the government never explaining why the agreement that the government itself negotiated is unsatisfactory), the CFIUS process in in which Petitioners have participated in good faith is geared toward finding any number of other less restrictive alternatives to an outright, total ban. The CFIUS member agencies could return to working with Petitioners to craft a solution that is tailored to meet the government's concerns and that is commercially, technologically, and legally feasible. Yet the government has not explained why the CFIUS process is not a viable alternative. 77. There are also a wide range of other less restrictive measures that Congress could have enacted. While many of these measures are themselves unjustified as applied to Petitioners, they nevertheless. illustrate that the Act does not select the least restrictive means to 46 (Page 47 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 48 of 70 further the national security goals that appear to have motivated it. For example, Congress could have addressed some members' stated concern about Tik Tok allegedly "track[ing] the locations of Federal employees and contractors" 23 by expanding the existing ban on government-owned devices to cover personal devices of federal employees and contractors. Or Congress could have enacted legislation to regulate TikTok's access to measures the Department of certain features on users' devices Homeland Security identified in 2020 as potential mitigations to "reduce the national security risks associated with" TikTok.24 78. Of course, Congress could also have decided not to single out a single speech platform (TikTok) and company (ByteDance Ltd.), and instead pursued any number of industry-wide regulations aimed at addressing the industry-wide issues of data security and content integrity. Congress could have enacted a data protection law governing transfers of Americans' sensitive data to foreign countries, similar to the 23 House Committee Report at 6. 24 Cybersecurity and Infrastructure Agency, Critical Infrastructure Security and Resilience Note, Appendix B: Department of Homeland Security Tik Tok and WeChat Risk Assessment 4 (Sept. 2, 2020). 47 (Page 48 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 49 of 70 strategy President Biden is currently pursuing through executive - the order. 25 Indeed, Congress did enact such a data-transfer law similarly named "Protecting Americans' Data from Foreign Adversaries Act of 2024" as the very next division of the legislation that contains the Act. Yet it chose to prohibit only “data broker[s]” from “mak[ing] available personally identifiable sensitive data of a United States. individual to any foreign adversary country or ... any entity that is controlled by a foreign adversary." H.R. 815, div. I, § 2(a), 118th Cong., Pub. L. No. 118-50 (Apr. 24, 2024). 79. There are also models for industry-wide regulation that Congress could have followed from other jurisdictions. For example, the European Union's Digital Services Act requires certain platforms to make disclosures about their content-moderation policies and to provide regulators and researchers with access to their data so those researchers can assess if the platforms are systemically promoting or suppressing 25 See Exec. Order 14, 117, 89 Fed. Reg. 15421 (Mar. 1, 2024). 48 (Page 49 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 50 of 70 content with particular viewpoints. 26 Congress pursued none of these alternatives. 80. Congress did not even provide Petitioners with the process and fact-finding protections that the Act extends to all other companies -protections which themselves likely fall short of what the Constitution mandates. Other companies receive prior notice, followed by a presidential determination of (and public report on) the national security threat posed by the targeted application, and the submission to Congress. of classified evidence supporting that determination, Sec. 2(g)(3)(B), which then is subject to judicial review based on the actual reasons for the decision, not post hoc rationalizations. 81. Because Congress failed to try any of these less restrictive measures, or at a minimum to explain why these alternatives would not address the government's apparent concerns, the Act is not narrowly tailored. 82. The Act independently fails strict scrutiny because it is both under- and over-inclusive. The Act is under-inclusive because it 26 EU Reg. 2022/2065 arts. 15, 40(4), 42(2). 49 (Page 50 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 51 of 70 ignores the many ways in which other companies. - both foreign and domestic can pose the same risks to data security and promotion of misinformation supposedly posed by Petitioners. The government "cannot claim" that banning some types of foreign owned applications is "necessary" to prevent espionage and propaganda “while at the same time" allowing other types of platforms and applications that may "create the same problem.” Reed, 576 U.S. at 172. Put differently, the Act's “[u]nderinclusiveness raises serious doubts about whether the government is in fact pursuing the interest it invokes, rather than disfavoring a particular speaker or viewpoint.” Brown v. Ent. Merchants Ass'n, 564 U.S. 786, 802 (2011). 83. Most glaringly, the Act applies only to Petitioners and certain other platforms that allow users to generate and view "text, images, videos, real-time communications, or similar content.” Sec. 2(g)(2)(A). The Act's coverage is thus triggered not by whether an application. collects users' data, but whether it shows them “content." Accordingly, there is no necessary relationship between the Act's scope and Congress's apparent concern with risks to Americans' data security, which could (Page 51 of Total) 50

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 52 of 70 equally be posed by personal finance, navigation, fitness, or many other types of applications. 84. The Act also singles out Petitioners by exempting all other companies that operate any website or application "whose primary purpose is to allow users to post product reviews, business reviews, or travel information and reviews." Sec. 2(g)(2)(B). But the Act does not explain why such applications, when (i) “foreign adversary controlled” under the Act's broad definition; and (ii) determined by the President to be a significant national security threat, could not likewise be used to collect data from Americans such as Americans' location information - or to spread misinformation. Nor does the Act explain why an entire company presents no threat simply because it operates a single website or application the “primary purpose” of which is posting “product reviews, business reviews, or travel information and reviews." Sec. 2(g)(2)(B). The Act's differential treatment of this favored category of websites and applications also disregards the fact that there is voluminous content on Tik Tok containing product reviews, business reviews, and travel information and reviews. Yet TikTok and all ByteDance applications are ineligible for this exclusion. 51 (Page 52 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 53 of 70 85. More broadly, the Act ignores the reality that much of the data collected by Tik Tok is no different in kind from the data routinely collected by other applications and sources in today's online world, including by American companies like Google, Snap, and Meta. The Act also ignores that foreign countries, including China, can obtain such information on Americans in other ways such as through open-source research and hacking operations. 86. Likewise, the House Committee Report on an earlier version of the Act speculates that allowing source code development in China "potentially exposes U.S. users to malicious code, backdoor vulnerabilities, surreptitious surveillance, and other problematic activities tied to source code development."27 But those supposed risks arise for each of the many American companies that employ individuals in China to develop code. The Act, however, does not seek to regulate, much less prohibit, all online applications offered by companies that have offices in China or that otherwise employ Chinese nationals as software developers. 28 27 House Committee Report at 5. 28 See, e.g., Karen Freifeld & Jonathan Stempel, Former Google Engineer 52 (Page 53 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 54 of 70 87. Nor does the Act seek to cut off numerous other ways that Americans could be exposed to foreign propaganda. For instance, the Act leaves foreign nationals (and even adversarial governments themselves) free to operate cable television networks in the United States, spread propaganda through accounts on other online platforms that enable the sharing of user-generated content, or distribute copies of state-run newspapers physically or over the Internet (including by software applications) in the United States. 29 Indicted for Stealing AI Secrets to Aid Chinese Companies, Reuters (Mar. 6, 2024), https://perma.cc/6LYE-64J6. 29 The U.S. government has recognized that foreign government. propaganda is an industry-wide challenge for online platforms. See, e.g., Nat'l Intel. Council, Declassified Intelligence Community Assessment, Foreign Threats to the 2020 US Federal Elections (Mar. 10, 2021), https://perma.cc/VD3Y-VXSB. YouTube, for example, added disclaimers to certain channels that were reportedly being used to spread disinformation on behalf of the Russian government. Paresh Dave & Christopher Bing, Russian Disinformation on YouTube Draws Ads, Lacks Warning Labels - Researchers, Reuters (June 7, 2019), https://perma.cc/2BEJ-VKGW. Like others in the industry, TikTok publishes transparency reports on attempts by users to use the platform for government propaganda purposes. See TikTok, Countering Influence Operations (last visited May 6, 2024), https://perma.cc/AB39-S8FJ. 53 (Page 54 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 55 of 70 88. The Act is also over-inclusive because it applies to other Byte Dance Ltd.-owned applications that Congress has not shown and could not possibly prove pose the risks the Act apparently seeks to address. - 89. At a minimum, the Act fails intermediate scrutiny. Even if strict scrutiny did not apply, the Act would still fail intermediate scrutiny as a time, place, and manner restriction: the Act prohibits speech activity on TikTok at all times, in all places, and in all manners anywhere across the United States. To pass intermediate scrutiny, a law must be "narrowly tailored to serve a significant governmental interest.” McCullen v. Coakley, 573 U.S. 464, 486 (2014). This means that it must not "burden substantially more speech than is necessary to further the government's legitimate interests," Turner, 512 U.S. at 661-62, and "leave open ample alternative channels for communication of the information," Clark v. Cmty. for Creative Non-Violence, 468 U.S. 288, 293 (1984). 90. For many of the same reasons the Act cannot satisfy strict scrutiny, it also cannot satisfy intermediate scrutiny: (Page 55 of Total) 54

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 56 of 70 91. As discussed supra ¶¶67-69, the government has failed to establish that its apparent data security and propaganda concerns with Tik Tok are non-speculative. And as discussed supra ¶¶ 73-81, the Act. burdens substantially more speech than necessary because there are many less restrictive alternatives Congress could have adopted to address any legitimate concerns. The Act also fails intermediate scrutiny because it “effectively prevents” TikTok Inc. “from reaching [its] intended audience" and thus "fails to leave open ample alternative means of communication." Edwards v. City of Coeur d'Alene, 262 F.3d 856, 866 (9th Cir. 2001). 92. Regardless of the level of scrutiny, the Act violates the First Amendment for two additional reasons. 93. The Act forecloses an entire medium of expression. First, by banning TikTok in the United States, the Act "foreclose[s] an entire medium of expression." City of Ladue v. Gilleo, 512 U.S. 43, 56 (1994). A "long line of Supreme Court cases indicates that such laws are almost never reasonable." Anderson v. City of Hermosa Beach, 621 F.3d 1051, 1064-65 (9th Cir. 2010). (Page 56 of Total) 55

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 57 of 70 94. The Act is constitutionally overbroad. Second, the Act is facially overbroad. A law is "overbroad if a substantial number of its. applications are unconstitutional, judged in relation to the statute's plainly legitimate sweep." United States v. Stevens, 559 U.S. 460, 473 (2010) (citation omitted). Here, for example, the government has never contended that all or even most of the content on TikTok (or any other Byte Dance-owned application) represents misinformation, or propaganda. Yet the Act shuts down all speech on ByteDance-owned applications at all times, in all places, and in all manners. That is textbook overbreadth. See, e.g., Bd. of Airport Comm'rs v. Jews for Jesus, Inc., 482 U.S. 569, 574–75 (1987). disinformation, Ground 2: Unconstitutional Bill of Attainder 95. The Act is an unconstitutional bill of attainder. Article I of the U.S. Constitution prohibits Congress from passing any bill of attainder. U.S. Const. art. I § 9, cl. 3 ("No Bill of Attainder or ex post facto Law shall be passed."). A bill of attainder is "legislative punishment, of any form or severity, of specifically designated persons or groups." United States v. Brown, 381 U.S. 437, 447 (1965). The protection against bills of attainder is “an implementation of 56 (Page 57 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 58 of 70 the separation of powers, a general safeguard against legislative exercise of the judicial function, or more simply trial by legislature." Id. at 442. - 97. By singling out Petitioners for legislative punishment, the Act is an unconstitutional bill of attainder. 98. The Act inflicts "pains and penalties" that historically have been associated with bills of attainder. See Nixon v. Adm'r of Gen. Servs., 433 U.S. 425, 474 (1977). Historically, common "pains and penalties" included "punitive confiscation of property by the sovereign” and “a legislative enactment barring designated individuals or groups from participation in specified employments or vocations," among others. Id. As described above, the Act confiscates Petitioners' U.S. businesses by forcing ByteDance to shutter them within 270 days or sell on terms that are not commercially, technologically, or legally feasible. See supra ¶¶26-29. For the same reason, the Act bars Petitioners from operating in their chosen line of business. 99. "[V]iewed in terms of the type and severity of burdens imposed" on Petitioners, the Act's treatment of Petitioners cannot "reasonably ... be said to further nonpunitive legislative purposes." Nixon, 433 U.S. at 475–76. The Act transforms Petitioners into a “vilified 57 (Page 58 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 59 of 70 class" by explicitly prohibiting their current and future operations in the United States, without qualification or limitation, but does not extend the same treatment to other similarly situated companies. Foretich v. United States, 351 F.3d 1198, 1224 (D.C. Cir. 2003). 100. Moreover, in light of the less restrictive alternatives discussed above, there is no justification for automatically barring Petitioners' current and future operations in the United States (or those of its subsidiaries or successors) in perpetuity without providing them a meaningful opportunity to take corrective action. See Kaspersky Lab, Inc. v. U.S. Dep't of Homeland Sec., 909 F.3d 446, 456 (D.C. Cir. 2018). Indeed, the Act imposes this punishment uniquely on Petitioners without the process, and presidential determination of a significant national security threat, that Congress has afforded to everyone else. Expressly singling out Petitioners for these punitive burdens while at the same time adopting a statutory standard and decision-making process applicable to every other entity makes clear that Petitioners are subjected to a prohibited legislatively imposed punishment. 101. Moreover, while Petitioners can avoid the Act's prohibitions only via a wholesale divestment, all other companies 58 even those with (Page 59 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 60 of 70 Chinese ownership and determined by the President to present a "significant threat" to U.S. national security ― can avoid prohibition simply by operating a website or an application "whose primary purpose is to allow users to post product reviews, business reviews, or travel information and reviews." Sec. 2(g)(2)(b). 102. Indeed, any other "adversary-controlled" company that operates an application exactly like TikTok, but also operates a website the primary purpose of which is to post product reviews, is left untouched, leaving a ready path for any company but those affiliated with Petitioners to circumvent the Act's prohibitions altogether. For all practical purposes, then, the Act applies to just one corporate group is a "Tik Tok bill," as congressional leaders have described it.30 - it 103. For all of these reasons, the Act constitutes an unconstitutional bill of attainder. 30 Rachel Dobkin, Mike Johnson's Letter Sparks New Flood of Republican Backlash, Newsweek (Apr. 17, 2024), https://perma.cc/Z5HD-7UVU (quoting letter from Speaker Johnson referencing the “TikTok_bill”); Senator Chuck Schumer, Majority Leader, to Colleagues (Apr. 5, 2024), https://perma.cc/J7Q4-9PGJ (referencing “TikTok legislation”). 59 (Page 60 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 61 of 70 Ground 3: Violation of Equal Protection 104. The Act also violates Petitioners' rights under the equal protection component of the Fifth Amendment's Due Process Clause because it singles Petitioners out for adverse treatment without any reason for doing so. 105. First, the Act deems any application offered by Petitioners to be a “foreign adversary controlled application" without notice or a presidential determination. Sec. 2(g)(3)(A). By contrast, applications offered by other companies "controlled by a foreign adversary" are deemed to be "foreign adversary controlled applications" only after notice. and a presidential determination that those companies present "significant threat[s]" to U.S. national security, a determination that must be supported by evidence submitted to Congress. Sec. 2(g)(2)(B); see supra 34(d). 106. That distinction imposes a dramatically heavier burden on Petitioners' free speech rights without any justification. The Act precludes the government from burdening the speech rights of any speakers other than Petitioners unless and until the President issues a public report on the specific national security concerns animating the 60 (Page 61 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 62 of 70 President's decision, provides support for that decision, and describes the assets requiring divestiture. Those protections ensure that the President must, at the very least, provide a detailed national security justification for his or her actions before burdening other speakers' speech a justification that then will provide the basis for judicial review. The Act imposes none of those requirements as a precondition for burdening Petitioners' speech it levies that burden by unexplained legislative fiat. — 107. Second, the Act denies Petitioners the exemption available to any other company that is purportedly “controlled by a foreign adversary." As noted, any application Petitioners offer is ipso facto deemed a "foreign adversary controlled application." By contrast, other companies "controlled by a foreign adversary" are exempt from the Act's definition of a "covered company," and thus from the Act's requirements, so long as they offer at least one application with the "primary purpose" of “allow[ing] users to post product reviews, business reviews, or travel information and reviews." Sec. 2(g)(2)(B). 108. There is no conceivable reason for treating Petitioners differently than all other similarly situated companies. Even if Congress 61 (Page 62 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 63 of 70 had valid interests in protecting U.S. users' data and controlling what content may be disseminated through global platforms that would be advanced through the Act, there is no reason why those concerns would support a ban on Petitioners' platforms without corresponding bans on other platforms. Nor is there any rational reason why Congress would ban Petitioners' platforms while allowing any other company "controlled by a foreign adversary" - regardless of the national security threat posed by that company to sidestep the Act's reach by simply offering an - application that “allows users to post product reviews, business reviews, or travel information and reviews," but changing nothing else about the company's operations, ownership structure, or other applications. 109. By treating Petitioners differently from others similarly situated, the Act denies Petitioners the equal protection of the law. Ground 4: Unconstitutional Taking 110. The Act effects an unlawful taking of private property without just compensation, in violation of the Fifth Amendment's Takings Clause. 111. The Takings Clause provides that “private property” shall not be "taken for public use, without just compensation." U.S. Const. amend. V, cl. 5. The Act does just that by shutting down ByteDance's 62 (Page 63 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 64 of 70 U.S. businesses or, to the extent any qualified divestiture alternative is even feasible (it is not), compelling ByteDance to sell those businesses. under fire-sale circumstances that guarantee inadequate compensation. 112. Petitioners have substantial property interests in, and associated with, their and their affiliates' U.S. operations. These include not only ByteDance Ltd.'s interest in TikTok Inc. and other U.S. businesses, but also the platforms and applications themselves. See Kimball Laundry Co. v. United States, 338 U.S. 1, 11–13 (1949) (Takings Clause also protects losses to going-concern value of business). 113. If the Act's prohibitions take effect, they will deprive Petitioners of property protected by the Takings Clause. Absent a qualified divestiture, the Act will shutter Petitioners' businesses in the United States. And even if a qualified divestiture were feasible (it is not), any sale could be, at best, completed only at an enormous discount to the U.S. businesses' current market value, given the forced sale conditions. See BFP v. Resol. Tr. Corp., 511 U.S. 531, 537 (1994) (“[M]arket value, as it is commonly understood, has no applicability in the forced-sale context; indeed, it is the very antithesis of forced-sale value."). (Page 64 of Total) 63

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 65 of 70 114. Because the Act compels ByteDance "to relinquish specific, identifiable property" or forfeit "all economically beneficial uses," the Act effects a per se taking. Horne v. Dep't of Agric., 576 U.S. 350, 364-65 (2015); Lucas v. S.C. Coastal Council, 505 U.S. 1003, 1019 (1992). 115. Alternatively, the Act inflicts a regulatory taking. Even when a law does not compel the physical invasion of property or deprive the property of all economically viable use, it still effects a taking "if [it] goes too far." Penn. Coal Co. v. Mahon, 260 U.S. 393, 415 (1922). In determining when a law "goes too far," courts have typically looked to "several factors" identified in Penn Central Transportation Co. v. City of New York, 438 U.S. 104, 124 (1978), namely, (a) “[t]he economic impact of the regulation”; (b) “the extent to which the regulation has interfered with reasonable investment-backed expectations"; and (c) "the character of the governmental action." The Act inflicts a regulatory taking under each of these three factors. 116. The Act does not compensate Petitioners (let alone provide just compensation) for the dispossession of their U.S. businesses. See United States v. Miller, 317 U.S. 369, 373 (1943). Prospective injunctive (Page 65 of Total) 64

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 66 of 70 relief is accordingly warranted. See, e.g., Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579, 585 (1952). Requested Relief relief: Petitioners respectfully request that this Court grant the following A. Issue a declaratory judgment that the Act violates the U.S. Constitution; B. Issue an order enjoining the Attorney General from enforcing the Act; C. Enter judgment in favor of Petitioners; and D. Grant any further relief that may be appropriate. (Page 66 of Total) 65

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 67 of 70 DATED: May 7, 2024 Andrew J. Pincus Avi M. Kupfer MAYER BROWN LLP 1999 K Street, NW Washington, DC 20006 Telephone: 202-263-3220 Email: [email protected] [email protected] Respectfully submitted, /s/ Alexander A. Berengaut Alexander A. Berengaut David M. Zionts Megan A. Crowley COVINGTON & BURLING LLP One CityCenter 850 Tenth Street, NW Washington, DC 20001 Telephone: (202) 662-6000 Email: [email protected] [email protected] [email protected] John E. Hall Anders Linderot COVINGTON & BURLING LLP The New York Times Building 620 Eighth Avenue New York, New York 10018 Telephone: (212) 841-1000 Email: [email protected] [email protected] Counsel for Petitioners (Page 67 of Total) 66

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 68 of 70 IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT TIKTOK INC., and BYTEDANCE LTD., V. ) Petitioners, No. 24-1113 MERRICK B. GARLAND, in his official capacity as Attorney General of the United States, Respondent. CORPORATE DISCLOSURE STATEMENT Petitioners state as follows: ByteDance Ltd. is a privately held corporation incorporated in the Cayman Islands. ByteDance Ltd. subsidiaries provide a suite of more than a dozen products and services that allow people to connect with, create, and consume content on the Internet. ByteDance Ltd. has no (Page 68 of Total) 1

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 69 of 70 parent company, and no publicly traded company owns 10% or more of Byte Dance Ltd.'s stock. Tik Tok Inc. is a California-incorporated company that provides the TikTok platform in the United States. TikTok Inc. is a wholly owned subsidiary of TikTok LLC, which is a wholly owned subsidiary of TikTok Ltd. TikTok Ltd. is a wholly owned subsidiary of ByteDance Ltd. TikTok Inc. has no other parent company, and no publicly held corporation owns 10% or more of its stock. (Page 69 of Total) 2 /s/Alexander A. Berengaut Alexander A. Berengaut Counsel for Petitioners

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 70 of 70 CERTIFICATE OF SERVICE I hereby certify that on this 7th day of May, I caused copies of the foregoing Petition for Review and Corporate Disclosure Statement to be served upon the following recipients. By certified mail, postage prepaid: Merrick B. Garland Attorney General of the United States U.S. Department of Justice 950 Pennsylvania Avenue, NW Washington, DC 20530 By hand delivery: Matthew M. Graves United States Attorney 601 D Street, NW Washington, DC 20579 /s/ Alexander A. Berengaut Alexander A. Berengaut Counsel for Petitioners (Page 70 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 1 of 7 (Page 71 of Total) EXHIBIT A

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 2 of 7 (Page 72 of Total) H. R. 815-61 Fusion Development Strategy programs of the People's Republic of China, including the following: (1) A brief summary of each such identified field and its relevance to the military power and national security of the People's Republic of China. (2) The implications for the national security of the United States as a result of the leadership or dominance by the People's Republic of China in each such identified field and associated supply chains. (3) The identification of at least 10 entities domiciled in, controlled by, or directed by the People's Republic of China (including any subsidiaries of such entity), involved in each such identified field, and an assessment of, with respect to each such entity, the following: (A) Whether the entity has procured components from any known United States suppliers. (B) Whether any United States technology imported by the entity is controlled under United States regulations. (C) Whether United States capital is invested in the entity, either through known direct investment or passive investment flows. (D) Whether the entity has any connection to the Peo- ple's Liberation Army, the Military-Civil Fusion program of the People's Republic of China, or any other state-spon- sored initiatives of the People's Republic of China to sup- port the development of national champions. (c) APPROPRIATE CONGRESSIONAL COMMITTEES DEFINED.-In this section, the term "appropriate congressional committees" means- (1) the Committee on Foreign Affairs of the House of Rep- resentatives; (2) the Committee on Armed Services of the House of Representatives; (3) the Committee on Foreign Relations of the Senate; and (4) the Committee on Armed Services of the Senate. DIVISION H-PROTECTING AMERICANS FROM FOREIGN ADVERSARY CON- TROLLED APPLICATIONS ACT SEC. 1. SHORT TITLE. This division may be cited as the "Protecting Americans from Foreign Adversary Controlled Applications Act”. SEC. 2. PROHIBITION OF FOREIGN APPLICATIONS. ADVERSARY CONTROLLED (a) IN GENERAL.— (1) PROHIBITION OF FOREIGN ADVERSARY CONTROLLED APPLICATIONS.-It shall be unlawful for an entity to distribute, maintain, or update (or enable the distribution, maintenance, or updating of) a foreign adversary controlled application by carrying out, within the land or maritime borders of the United States, any of the following:

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 3 of 7 (Page 73 of Total) H. R. 815-62 (A) Providing services to distribute, maintain, or update such foreign adversary controlled application (including any source code of such application) by means of a marketplace (including an online mobile application store) through which users within the land or maritime borders of the United States may access, maintain, or update such application. (B) Providing internet hosting services to enable the distribution, maintenance, or updating of such foreign adversary controlled application for users within the land or maritime borders of the United States. (2) APPLICABILITY.-Subject to paragraph (3), this sub- section shall apply― (A) in the case of an application that satisfies the definition of a foreign adversary controlled application pursuant to subsection (g)(3)(A), beginning on the date that is 270 days after the date of the enactment of this division; and (B) in the case of an application that satisfies the definition of a foreign adversary controlled application pursuant to subsection (g)(3)(B), beginning on the date that is 270 days after the date of the relevant determination of the President under such subsection. (3) EXTENSION. With respect to a foreign adversary con- trolled application, the President may grant a 1-time extension of not more than 90 days with respect to the date on which this subsection would otherwise apply to such application pursuant to paragraph (2), if the President certifies to Congress that- (A) a path to executing a qualified divestiture has been identified with respect to such application; (B) evidence of significant progress toward executing such qualified divestiture has been produced with respect to such application; and (C) there are in place the relevant binding legal agree- ments to enable execution of such qualified divestiture during the period of such extension. (b) DATA AND INFORMATION PORTABILITY TO ALTERNATIVE APPLICATIONS.-Before the date on which a prohibition under sub- section (a) applies to a foreign adversary controlled application, the entity that owns or controls such application shall provide, upon request by a user of such application within the land or maritime borders of United States, to such user all the available data related to the account of such user with respect to such application. Such data shall be provided in a machine readable format and shall include any data maintained by such application with respect to the account of such user, including content (including posts, photos, and videos) and all other account information. (c) EXEMPTIONS.— (1) EXEMPTIONS FOR QUALIFIED DIVESTITURES.-Subsection (a)— (A) does not apply to a foreign adversary controlled application with respect to which a qualified divestiture is executed before the date on which a prohibition under subsection (a) would begin to apply to such application; and

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 4 of 7 (Page 74 of Total) H. R. 815-63 (B) shall cease to apply in the case of a foreign adversary controlled application with respect to which a qualified divestiture is executed after the date on which a prohibition under subsection (a) applies to such applica- tion. (2) EXEMPTIONS FOR CERTAIN NECESSARY SERVICES.-Sub- sections (a) and (b) do not apply to services provided with respect to a foreign adversary controlled application that are necessary for an entity to attain compliance with such sub- sections. (d) ENFORCEMENT.— (1) CIVIL PENALTIES.― (A) FOREIGN ADVERSARY CONTROLLED APPLICATION VIO- LATIONS. An entity that violates subsection (a) shall be subject to pay a civil penalty in an amount not to exceed the amount that results from multiplying $5,000 by the number of users within the land or maritime borders of the United States determined to have accessed, maintained, or updated a foreign adversary controlled application as a result of such violation. (B) DATA AND INFORMATION VIOLATIONS.-An entity that violates subsection (b) shall be subject to pay a civil penalty in an amount not to exceed the amount that results from multiplying $500 by the number of users within the land or maritime borders of the United States affected by such violation. (2) ACTIONS BY ATTORNEY GENERAL.-The Attorney Gen- eral- (A) shall conduct investigations related to potential violations of subsection (a) or (b), and, if such an investiga- tion results in a determination that a violation has occurred, the Attorney General shall pursue enforcement under paragraph (1); and (B) may bring an action in an appropriate district court of the United States for appropriate relief, including civil penalties under paragraph (1) or declaratory and injunctive relief. (e) SEVERABILITY.― (1) IN GENERAL.-If any provision of this section or the application of this section to any person or circumstance is held invalid, the invalidity shall not affect the other provisions or applications of this section that can be given effect without the invalid provision or application. (2) SUBSEQUENT DETERMINATIONS.-If the application of any provision of this section is held invalid with respect to a foreign adversary controlled application that satisfies the definition of such term pursuant to subsection (g)(3)(A), such invalidity shall not affect or preclude the application of the same provision of this section to such foreign adversary con- trolled application by means of a subsequent determination pursuant to subsection (g)(3)(B). (f) RULE OF CONSTRUCTION.-Nothing in this division may be construed― (1) to authorize the Attorney General to pursue enforce- ment, under this section, other than enforcement of subsection (a) or (b);

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 5 of 7 (Page 75 of Total) H. R. 815-64 (2) to authorize the Attorney General to pursue enforce- ment, under this section, against an individual user of a foreign adversary controlled application; or (3) except as expressly provided herein, to alter or affect any other authority provided by or established under another provision of Federal law. (g) DEFINITIONS.-In this section: (1) CONTROLLED BY A FOREIGN ADVERSARY.-The term "con- trolled by a foreign adversary" means, with respect to a covered company or other entity, that such company or other entity is- (A) a foreign person that is domiciled in, is headquartered in, has its principal place of business in, or is organized under the laws of a foreign adversary country; (B) an entity with respect to which a foreign person or combination of foreign persons described in subpara- graph (A) directly or indirectly own at least a 20 percent stake; or (C) a person subject to the direction or control of a foreign person or entity described in subparagraph (A) or (B). (2) COVERED COMPANY.— (A) IN GENERAL.—The term "covered company" means an entity that operates, directly or indirectly (including through a parent company, subsidiary, or affiliate), a website, desktop application, mobile application, or aug- mented or immersive technology application that— (i) permits a user to create an account or profile to generate, share, and view text, images, videos, real- time communications, or similar content; (ii) has more than 1,000,000 monthly active users with respect to at least 2 of the 3 months preceding the date on which a relevant determination of the President is made pursuant to paragraph (3)(B); (iii) enables 1 or more users to generate or dis- tribute content that can be viewed by other users of the website, desktop application, mobile application, or augmented or immersive technology application; and (iv) enables 1 or more users to view content gen- erated by other users of the website, desktop applica- tion, mobile application, or augmented or immersive technology application. (B) EXCLUSION.—The term “covered company” does not include an entity that operates a website, desktop applica- tion, mobile application, or augmented or immersive tech- nology application whose primary purpose is to allow users to post product reviews, business reviews, or travel information and reviews. a (3) FOREIGN ADVERSARY CONTROLLED APPLICATION.―The term "foreign adversary controlled application" means website, desktop application, mobile application, or augmented or immersive technology application that is operated, directly or indirectly (including through a parent company, subsidiary, or affiliate), by— (A) any of (i) ByteDance, Ltd.;

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 6 of 7 (Page 76 of Total) (ii) TikTok; H. R. 815-65 (iii) a subsidiary of or a successor to an entity identified in clause (i) or (ii) that is controlled by a foreign adversary; or (iv) an entity owned or controlled, directly or indirectly, by an entity identified in clause (i), (ii), or (iii); or (B) a covered company that- (i) is controlled by a foreign adversary; and (ii) that is determined by the President to present a significant threat to the national security of the United States following the issuance of (I) a public notice proposing such determina- tion; and (II) a public report to Congress, submitted not less than 30 days before such determination, describing the specific national security concern involved and containing a classified annex and a description of what assets would need to be divested to execute a qualified divestiture. (4) FOREIGN ADVERSARY COUNTRY.-The term “foreign adversary country" means a country specified in section 4872(d)(2) of title 10, United States Code. (5) INTERNET HOSTING SERVICE.―The term "internet hosting service" means a service through which storage and computing resources are provided to an individual or organiza- tion for the accommodation and maintenance of 1 or more websites or online services, and which may include file hosting, domain name server hosting, cloud hosting, and virtual private server hosting. (6) QUALIFIED DIVESTITURE.—The term "qualified divesti- ture" means a divestiture or similar transaction that- (A) the President determines, through an interagency process, would result in the relevant foreign adversary controlled application no longer being controlled by a for- eign adversary; and (B) the President determines, through an interagency process, precludes the establishment or maintenance of any operational relationship between the United States operations of the relevant foreign adversary controlled application and any formerly affiliated entities that are controlled by a foreign adversary, including any cooperation with respect to the operation of a content recommendation algorithm or an agreement with respect to data sharing. (7) SOURCE CODE.-The term "source code" means the com- bination of text and other characters comprising the content, both viewable and nonviewable, of a software application, including any publishing language, programming language, pro- tocol, or functional content, as well as any successor languages or protocols. (8) UNITED STATES.-The term "United States" includes the territories of the United States. SEC. 3. JUDICIAL REVIEW. (a) RIGHT OF ACTION.-A petition for review challenging this division or any action, finding, or determination under this division

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 7 of 7 (Page 77 of Total) H. R. 815-66 may be filed only in the United States Court of Appeals for the District of Columbia Circuit. (b) EXCLUSIVE JURISDICTION.-The United States Court of Appeals for the District of Columbia Circuit shall have exclusive jurisdiction over any challenge to this division or any action, finding, or determination under this division. (c) STATUTE OF LIMITATIONS.-A challenge may only be brought― (1) in the case of a challenge to this division, not later than 165 days after the date of the enactment of this division; and (2) in the case of a challenge to any action, finding, or determination under this division, not later than 90 days after the date of such action, finding, or determination. DIVISION I-PROTECTING AMERICANS' DATA FROM FOREIGN ADVERSARIES ACT OF 2024 SEC. 1. SHORT TITLE. This division may be cited as the "Protecting Americans' Data from Foreign Adversaries Act of 2024". SEC. 2. PROHIBITION ON TRANSFER OF PERSONALLY IDENTIFIABLE SENSITIVE DATA OF UNITED STATES INDIVIDUALS TO FOR- EIGN ADVERSARIES. (a) PROHIBITION.-It shall be unlawful for a data broker to sell, license, rent, trade, transfer, release, disclose, provide access to, or otherwise make available personally identifiable sensitive data of a United States individual to- (1) any foreign adversary country; or (2) any entity that is controlled by a foreign adversary. (b) ENFORCEMENT BY FEDERAL TRADE COMMISSION.― (1) UNFAIR OR DECEPTIVE ACTS OR PRACTICES.-A violation of this section shall be treated as a violation of a rule defining an unfair or a deceptive act or practice under section 18(a)(1)(B) of the Federal Trade Commission Act (15 U.S.C. 57a(a)(1)(B)). (2) POWERS OF COMMISSION.― (A) IN GENERAL.-The Commission shall enforce this section in the same manner, by the same means, and with the same jurisdiction, powers, and duties as though all applicable terms and provisions of the Federal Trade Commission Act (15 U.S.Č. 41 et seq.) were incorporated into and made a part of this section. (B) PRIVILEGES AND IMMUNITIES.-Any person who vio- lates this section shall be subject to the penalties and entitled to the privileges and immunities provided in the Federal Trade Commission Act. (3) AUTHORITY PRESERVED.-Nothing in this section may be construed to limit the authority of the Commission under any other provision of law. (c) DEFINITIONS.-In this section: (1) COMMISSION.-The term "Commission" means the Fed- eral Trade Commission.