Wind turbine company American Superconductor saw a huge opportunity to tap into the coveted Chinese marketplace after the Chinese government passed a renewable energy law in 2005. Partnering with the Chinese company Sinovel, American Superconductor provided the advanced computer software used to run the turbine, while Sinovel manufactured the turbine exterior.

The U.S. company made sure that the machine’s codes, which the company had spent years and millions of dollars to develop, were safe: Only a few employees had access to the codes, and the company kept them under layers of security. Yet in 2011, engineers were testing a new-generation software on Sinovel’s turbine when they noticed the blades didn’t stop spinning after the test. Looking into the turbine, the engineers found that Sinovel was running a version of the software that they had not yet released.

After an investigation of who leaked the codes, American Superconductor found the culprit: Austrian employee Dejan Karabasevic. The Chinese company had given him women, a nice apartment, and a $1.7 million contract in exchange for the codes. Karabasevic ended up confessing in Austrian court and spending a year in jail.

American Superconductor filed a lawsuit against Sinovel in China for $1.2 billion in damages, and the case is still tied up in Chinese court. CEO Daniel McGahn told CBS’ 60 Minutes that because of the stolen intellectual property (IP), he’s had to fire 600 of his 900 employees and lost $1 billion. Now American Superconductor is working in India, yet Sinovel is undercutting the company as it exports its copied turbines overseas: McGahn said on 60 Minutes the state of Massachusetts purchased a Sinovel wind turbine with federal stimulus money.

U.S. companies working in China have long complained in general terms about IP theft and unfair business practices in China: Counterfeit goods, pirated software, and theft of trade secrets worldwide cost the United States up to $600 billion each year, according to the Commission on the Theft of American Intellectual Property. Even more concerning, hacked designs of military weapons is a national security threat, allowing China to develop a high-tech military quickly. At the 19th party congress in October, President Xi Jinping stated China would have a world-class military by 2050.

In August, President Donald Trump called on U.S. Trade Representative Robert Lighthizer to investigate China’s IP practices and forced technology transfers, a move that could lead to sanctions on China. Experts believe the investigation is too little, too late, as China is already breaking new ground on the shoulders of U.S. tech. Plus, in order to make a strong case against China, Lighthizer will need the testimonies of U.S. companies in China, and most companies are unwilling to jeopardize their access to the Chinese market by speaking out. As of November, only six companies had spoken out, and most were smaller businesses describing already known incidents, the BBC reported.

IP THEFT IN CHINA comes in different forms, from the stores at Beijing’s Silk Market selling fake Coach purses to China’s J-20 stealth fighter jet, which shares a striking resemblance to the U.S. F-22, to China’s high-speed rail system, which was originally a partnership with Japanese and German companies and is now claimed by China as one of its “four great new inventions.”

Sometimes companies are hacked by China’s army of cyberattackers; sometimes technology transfer is a requirement for entry into the Chinese market; sometimes ideas and brands are flat-out copied and sold in China. Other times entrepreneurial Chinese businessmen squat on the Chinese names of well-known brands, awaiting their arrival into China. Chinese courts tend to side with Chinese nationals.

In 2014, a U.S. federal grand jury indicted five People’s Liberation Army officers of Unit 61398 for hacking 115 U.S. companies in industries such as aerospace, satellite and telecommunications, and information technology between 2006 and 2014. Housed in a nondescript building in Shanghai, the unit uses more than 1,000 servers and could employ thousands of staffers, according to internet security firm Mandiant.

In the case of the J-20 fighter jet, Su Bin, a Chinese national, helped hack into U.S. defense companies, including Boeing and Lockheed Martin, the maker of the F-22. Su worked with two Chinese military officers who would install malware on the computers of employees. Su would point out which files were useful, translate them into Chinese, then sell the information to Chinese-owned companies.

The U.S. government caught and sentenced Su to nearly four years in prison in 2016: His indictment noted Su stole data relating to the F-22 and F-35 fighter jets and C-17 transport aircraft. As a result, the Chinese-made J-20 fighter jet unveiled in 2017 has technology that would have taken decades for the country to figure out for itself.

Former President Barack Obama and President Xi Jinping agreed to stop commercial cyberespionage in 2015, and according to cybersecurity firm FireEye, the number of attacks from China-based groups dropped by 90 percent from 2014 to 2016. But the dip in attacks doesn’t tell the whole story: Remaining attacks are more focused, selectively grabbing important files rather than whole masses of data, FireEye noted. Other analysts believe military personnel had hacked U.S. corporations to make extra cash selling trade secrets to Chinese companies, and the number of attacks fell because Xi’s anti-corruption campaign scared them away from moonlighting.

ANOTHER COMPLAINT by U.S. companies is the forced transfer of new technology from U.S. to Chinese companies as a price of doing business in China. Chinese law requires foreign companies in industries such as energy, telecommunications, and automobile manufacturing to form joint ventures with Chinese partners, which leads to tech transfers.

China’s new cybersecurity law requires foreign companies operating in China to disclose information about their network equipment and software to the Chinese government. (Beijing claims the purpose is to fight hackers and keep data safe.) The law also requires companies to store data locally: In July, Apple announced it was building its first data center in Guizhou, partnering with the government-backed Guizhou-Cloud Big Data Industry.

John Frisbie, president of the US-China Business Council, in a statement called the transfer of technology “an acute concern of American companies in key sectors, who often must make difficult choices about managing the trade-off of technology sharing and access to the world’s second-largest economy.”

Meanwhile, the advent of e-commerce has caused the number of counterfeits and fakes to grow exponentially in online marketplaces like Taobao and social media platforms. It’s well-known that clothes purchased from a China-based seller online often won’t turn out looking like the advertised photos, and counterfeiters run free, tricking buyers around the world.

Joe Simone, an IP lawyer who has worked in China for 30 years, said this is a largely unregulated space, as governments don’t police online marketplaces effectively and most brand owners lack the resources to track down all the counterfeiters online.

The Chinese government has only recently started introducing e-commerce reforms, including the creation of a blacklist of IP offenders. “It’s a long time coming, and many wonder if it will be too little, too late,” Simone said. A new draft e-commerce law includes provisions that would create a “big hole in protection,” he said, by allowing vendors of fakes to fill out some paperwork and then continue selling their products until their case goes to court. And with the large number of violations appearing online in China, “almost nobody goes to court.”

WHAT DO YOU DO ABOUT A COUNTRY LIKE CHINA that refuses to obey international standards? Some in industry hope that as China starts to create its own IP, it will get stricter by itself, and in some cases that is happening. Others, including the Chinese government, believe the United States should use World Trade Organization mechanisms to resolve disputes before resorting to an investigation based on U.S. law. Yet U.S. Secretary of Commerce Wilbur Ross criticized the WTO for not being tough enough on China.

Steven Mosher, head of Population Research Institute and author of Bully of Asia, believes the investigation is a good idea but 15 years too late: “I’m glad we finally got serious about trying to stop the intellectual property theft from China that has resulted in the largest transfer of wealth in human history.” For too long, Mosher said, China has played the developing nation card in order to get favorable trade deals, but then they “violate the deal before the ink is dry on the paper.”

Others fear that the investigation can do little unless U.S. companies speak up. Business associations have spoken up to complain in general terms, but few companies are willing to risk their relationship with the Chinese government and their access to China’s 1.2 billion consumers. Without companies speaking up, the United States can’t take more targeted actions against China.

Instead, tech corporations like Google, Facebook, and Apple are ingratiating themselves to the Chinese government: Apple CEO Tim Cook gushed about working with China at the World Internet Conference, a summit the Chinese government uses to promote its censored internet.