"Digital Leviathan" and "Digital Commons": a comparative study of digital government development paths in China and the United States with consideration of privacy rights

Amid the global wave of digital government transformation, China and the United States have pursued markedly different development paths. This paper investigates the fundamental differences between the two countries approaches in terms of top-level design, technological applications, public participation, and the impact on privacy rights, as well as the underlying logic behind these differences. Through comparative case studies and policy text analysis, the research focuses on Chinas Health Code and One-Stop Online Services, alongside the EUs GDPR and Californias CCPA as core cases. The main findings are as follows: Chinas path is state-led and efficiency-oriented, producing highly effective governance tools but facing the risk of a Digital Leviathan; the U.S./EU path prioritizes rights and checks and balances, building a Digital Commons at the potential cost of efficiency. Both approaches must confront their respective challenges and explore avenues for dialogue and mutual learning.