Bike sharing is considered an environmental-friendly way of commuting.[1] It reduces people’s needs for driving and hence reduces carbon emission.[2] It also provides a solution to the “last mile” issue in urban commuting and promotes the development of the sharing economy.[3]

Despite the benefits of bike sharing, the boom and bust cycle of bike sharing in China has produced many bicycle graveyards — yards where huge amounts of dumped bikes are placed. This phenomenon prompts us to reconsider the benefits of bike sharing. In China, the emergence of bicycle graveyards was driven by blind capital expansion, which led to the oversupply of bikes in cities. The oversupply created tremendous waste which was vividly shown by the documentary No Place to Place.[4]

This article examines how the bike-sharing industry developed in China, the problems it caused, the business model of the industry, the flaw of the capital-driven business model, and regulations of the bike-sharing industry.

   I. Development of the bike-sharing industry in China

The most famous dockless bike-sharing business in China began as a campus startup. In September 2015, four Peking University graduates introduced dockless shared bikes called “ofo” on to the campus; their mission was to share bikes anytime and anywhere.[5] Ofo soon became popular in Peking University and was expanded to the campuses of other universities in Beijing.[6] In November 2016, ofo expanded outside of campuses to provide bike-sharing services in cities.[7] In April 2016, another major bike-sharing company Mobike launched its business.[8] In addition to ofo and Mobike, at least twenty-five other bike-sharing companies entered the market in 2016.[9]

The bike-sharing industry flourished in 2017. In the first half of 2017, many startups financed by venture capitals poured into the market; leaders in the bike-sharing industry included ofo, Mobike, Bluegogo, and Hellobike.[10] As of July 2017, there were nearly seventy bike-sharing companies.[11] As compared to the number of users during the first half of 2017, the number of bike-sharing users increased by 108.1% in the second half of 2017.[12] As of December 2017, there were 221 million bike-sharing users, bike sharing had covered major cities in China, and the industry expanded to twenty-one overseas countries.[13]

However, the market concentrated considerably in 2017.[14] In the second half of 2017, as competition tremendously increased, many middle-to-small size bike-sharing companies exited the market because of the lack of continuous funding by venture capitals.[15] Some companies were not able to refund deposits to their customers, which caused serious social problems.[16] At the end of 2017, ofo and Mobike became the two dominant companies in the bike-sharing market.[17]

After the boom in 2017, the bike-sharing industry experienced a bust in 2018. From the second half of 2017, many cities prohibited bike-sharing companies from increasing their distribution of bikes in the market.[18] In the first half of 2018, the increase rate in the number of bike-sharing users slowed down to 11% in comparison to the figure in December 2017.[19] In June 2018, the number of bike-sharing users reached 245 million, which constituted 30.6% of all Internet users.[20] However, as of March 2018, thirty-four of the seventy bike-sharing companies were bankrupt.[21]

Although many less competitive bike-sharing companies went bankrupt, some bike-sharing companies with plenty of financial resources survived. In the first half of 2018, Mobike was acquired by Meituan, Bluegogo was acquired by Didi, and Hellobike was invested in by Alibaba.[22] As the existing bike-sharing companies were supported by big financial groups, competition became even more fierce.

In the middle of 2019, because of the hardship associated with continuous financing, ofo faced a huge number of customer requests for refunds.[23] Ofo was unable to meet the immediate requests for refunds as sixteen million customers lined up to request the refunds.[24] It was reported that ofo could only handle around 3,500 customer refunds a day and consequently, it would take 12.5 years to complete all the refund requests.[25]

Currently, many bike-sharing companies charge reasonable fees based on the length of time of usage and they may waive deposits based on credit rating scores of customers.

   II. Problems of the bike-sharing industry in China

Bike sharing has brought efficiency to commuters and reduced carbon emissions. In 2017 the “bike sharing + subways” commuting model enhanced the efficiency of commuting by 17.9% when compared to private driving.[26] Bike sharing also reduced carbon emissions by around seven million tons with a total riding distance of around thirty billion kilometers in 2017.[27] However, bike sharing also has brought tremendous problems to the society in China, including an oversupply of bikes that caused a waste of resources, ugly cityscapes because of the disorderly parking of bikes, and insecurity associated with customer deposits.

1. Oversupply of bikes that caused a waste of resources

The vicious competition among bike-sharing companies caused an oversupply of bikes that went far beyond cities’ capacities. As of December 2017, the maximum number of bikes Beijing could tolerate was only 1.2 million;[28] however, bike-sharing companies distributed 2.35 million bikes in Beijing, more than twice of the city’s maximum capacity.[29] The oversupply problem existed in Shanghai as well. As of August 2017, there were 1.5 million shared bikes in Shanghai, more than twice the city’s maximum capacity of 600,000.[30]

As a result of the oversupply, many cities, including Beijing, Shanghai, Guangzhou, and Shenzhen, prohibited bike-sharing companies from increasing their distribution of bikes in the market.[31] From 2018 to September 2019, the number of shared bikes was reduced by at least 40% of its peak.[32] Tens of thousands of those bikes were dumped in bicycle graveyards.[33] These bikes were mostly non-functioning or parked in inappropriate areas of the city and thus were disposed of by city maintenance workers.[34] These bikes waited to be reclaimed by bike-sharing companies;[35] however, few were reclaimed and hence many bikes were stacked up dismally like graveyards.[36] The oversupply of shared bikes caused a daunting waste of resources.

2. Ugly cityscape because of the disorderly parking of bikes

Because there are generally no docks to park the shared bikes, customers parked bikes wherever they stopped. On many occasions, such bikes were parked disorderly in inappropriate places, such as fire exits.[37] The random parking of shared bikes also blocked sidewalks and motor-vehicle lanes, slowed down the traffic, and caused safety concerns.[38] Many cities have made rules to regulate the total number of shared bikes and the places where they are allowed to be parked.[39]

3. Insecurity of customer deposits

Some bike-sharing companies were unable to refund customers for deposits because of the lack of continuous funding. Excessive subsidies to customers were funded by venture capital investments.[40] Once investors realized that the projects were unsustainable investors stopped financing such projects, which caused a broke of the financial chains.[41] Short of continuous funding, bike-sharing companies took the risk of using customers’ deposits to cover their costs.[42] Consequently, when a large number of customers requested refunds of deposits, some companies did not have enough cashflow to fulfill their refund obligations.[43] Once the rumor spread in the market that certain bike-sharing companies were having problems of refunding customers’ deposits, more customers requested refunds.[44] This contentious effect made things even worse and customers lined up for refunds.[45] Many companies went bankrupt because investors no longer wanted to finance them and they could not refund customers.[46] The security of customer deposits became a serious problem that had a spillover effect on the whole society, causing social panic and chaos.

   III. The business model of bike-sharing industry in China

In the business model of bike-sharing industry, there were two cashflow sources: (1) the fees charged to customers and (2) income generated from customer deposits.

1. Fees charged from customers

When the competition was fierce, companies charged very little for using bikes because they all wanted to acquire a large number of users as quickly as possible. For example, in July 2017, Mobike charged a considerably low price of five yuan for unlimited use of bikes for three months.[47] In August 2017, ofo charged as low as one yuan for unlimited use of bikes for a month.[48] This business model was unsustainable because the fees charged from customers were not enough to pay for operational costs.

Around 2019, many of the surviving bike-sharing companies increased the fees for customers by charging them based upon the length of time they use the bikes.[49] For example, Hellobike and Mobike both charged one yuan per fifteen minutes.[50]

2. Income generated from customer deposits

Bike-sharing companies also took customers deposits for using bikes. For example, ofo charged each customer 99 yuan and Mobike charged customers 299 yuan as a deposit.[51] The deposits could be refunded per customers’ requests but often customers would not request a refund because they still wanted to use the bikes.[52] As a result, deposits from customers became a pool of funds from which the bike-sharing companies could earn interest from depositing customer funds in banks.[53] For example, under Mobike’s business model, one assumes that placing a new bike in the market will bring eight more customers and thus the company will get customer deposits of nearly 2,400 yuan (around 300 yuan per additional customer).[54] Thus, if Mobike places ten million new bikes in the market it will get around twenty-four billion yuan (2,400 yuan per bike) as deposits.[55] Mobike can then earn bank interest from such a huge pool of deposits. Because of the lack of regulations, some bike-sharing companies even used customer deposits to cover their operating costs and costs of subsidizing customers.[56]

However, cashflow from deposits was also unsustainable. As mentioned above, when ofo faced a large amount of customer requests for refund, it did not have enough cashflow to pay for all these requests because the company lacked continuous funding from investors. Because customers feared that they might not get their deposits back, a new business model of requiring no deposits emerged and became popular. In March 2018, Hellobike became the first bike-sharing company to offer shared bikes with no deposits nationwide.[57] Since then, more than ten bike-sharing companies offer free-deposits services based on customers’ credit rating scores.[58]

   IV. Why the capital-driven business model is flaw in the bike-sharing industry?

The bike-sharing industry in China was capital driven in the early stage of its development. However, investors needed to make profits. When the market became unsustainable and investors realized that their business model could not generate profits in the future, investors stopped providing any further financing. The problem lay in the flaw of the capital-driven business model.

First, a business model that relies on continuous inflow of capital is flawed because it does not allow investors to make profits in the long run, which makes the model unsustainable. As previously discussed, bike-sharing companies rely on continuous capital investments to cover their various costs. Their strategy was to distribute as many bikes as they could in hopes of achieving a dominant position so that they could raise the price to earn profits in the future. To achieve this, companies initially charged customers as little as possible. In many cases, the cost to customers was nominal or even free. When all competitors in the market did the same thing, it resulted in the oversupply of bikes and that was how the number of bikes in many cities was twice as many as the respective city’s maximum tolerance capacity.

Contrary to many bike-sharing companies’ expectations, it was difficult to dominate the market because the threshold for a competitor to enter the market was relatively low. Bikes were not super high-tech products to manufacture, thus nearly every entrepreneur that had the initial investment could launch a bike-sharing business quite easily. When a new competitor entered the market, it typically repeated the strategy of distributing as many bikes in the market as it could and setting the initial costs to customers as low as possible. Continuously facing new competitors, the existing bike-sharing companies could not raise prices as they expected because raising prices would certainly result in losing customers to new competitors. In such a vicious circle, no bike-sharing company could earn profits in the long run and investors soon realized this and stopped the financing. As result, many bike-sharing companies went bankrupt or had to sell the companies.

Second, a business model that relies on continuous inflow of capital is flawed because it ignores that a successful bike-sharing business does not simply rely on the provision of bikes, but also on the corresponding public space and infrastructure.[59] The public space that allows people to ride and park their bikes is finite. The city has a maximum capacity to allow shared bikes to exist. For example, as mentioned above, in 2017 Shanghai could only tolerate 600,000 shared bikes and Beijing could only tolerate 1.2 million bikes.[60] However, in 2017 the supply of shared bikes in these two cities reached 1.5 million and 2.35 million, respectively.[61] Such oversupply of shared bikes overcrowded the cities. It was a tremendous waste of resources because the supply of bikes exceeded market demand. In addition, it was expensive to disassemble these bikes accumulating in the bicycle graveyards and recycle them.[62]

   V. Regulations of the bike-sharing industry

After discussing the development of the bike-sharing industry in China, the problems it caused, and the flaw of the capital-driven business model that led to an oversupply of bikes, this section continues to examine the regulations China adopted or will adopt in the bike-sharing industry. The solution does not lie on one party alone, but requires the cooperation by all market participants, including the government, bike-sharing companies, and bike users.

1. National and local government regulations

A successful bike-sharing business does not simply rely on the provision of bikes, but also relies on the corresponding public space and infrastructure.[63] There are two ways to improve the government’s ability to supply the space: one is an expansion of city space for bike sharing, such as providing more bicycle lanes and more parking space; the other is to enhance the efficiency of the usage of existing space, such as regulating the distribution, parking, operating, and recycling of bikes.[64] Expansion of city space is more difficult as it requires development of infrastructure that may be time-consuming. On the other hand, establishing regulations to facilitate the efficient use of the existing space would be relatively easier to achieve.

On August 1, 2017, the Ministry of Transport of China and nine other ministerial departments issued the Guiding Opinions on Encouraging and Regulating the Development of Internet Bicycle Rental (“Guiding Opinions”).[65] As of July 2017, there were nearly seventy bike-sharing companies, more than sixteen million shared bikes had been distributed in the market, and there were more than 130 million total registered customers.[66] According to the Guiding Opinions, China’s bike-sharing industry had developed quickly and played a positive role in better satisfying the demand of the general public for commuting, effectively solving the “last mile” issue in urban commuting, and easing urban traffic jams.[67] The bike-sharing industry also had developed a green commuting system and had promoted the development of the sharing economy.[68] However, the Guiding Opinions also identified problems such as disorderly parking, ineffective operation and maintenance of bikes, non-implementation of the primary responsibility of bike-sharing companies, the risks of customer deposits, and information security.[69] Accordingly, the Guiding Opinions encouraged local governments and bike-sharing companies to follow the government guidance to establish an orderly market.[70] In response to the Guiding Opinions of the central government, many local governments, including Shanghai[71] and Guangzhou[72], adopted their own guiding opinions.

However, the Guiding Opinions and their corresponding local counterparts are not binding legal documents and hence bike-sharing companies still have leeway in deviating from the Guiding Options. To provide teeth to the regulations, some local governments plan to establish local laws that govern this issue.[73] The following part of the article discusses the Guiding Opinions and the proposed Shenzhen legislation on the bike-sharing industry.

2. Areas subject to Government Regulations

Generally, there are nine areas that are subject to governments regulations in the bike-sharing industry. This part of the article discusses those areas.

a. Increasing the bicycle lanes

According to the Guiding Opinions, the government shall establish more bicycle lanes and make them more accessible to bike users.[74] The government shall also make road signs visible for bike users and remove objects that illegally occupy non-motor vehicle lanes to ensure the good conditions of cycling.[75] To implement the Guiding Opinions, the proposed Shenzhen legislation further provides that the local transportation authority shall include bicycle lanes and parking areas for bikes into their plans for city commuting system.[76]

b. Orderly distribution of bikes

According to the Guiding Opinion, each city shall establish a bicycle distribution mechanism to match the urban space tolerance capability, parking facility resources, and the demand of the general public for commuting.[77] The city government shall provide guidance to bike-sharing companies for distributing bikes in a reasonable and orderly manner.[78] It shall also ensure the sound and orderly development and the safe and stable operation of the industry.[79]

In the proposed Shenzhen legislation, the city plans to regulate the total number of bikes that can be distributed in the city and allocate a quota to qualified bike-sharing companies.[80] Bike-sharing companies will apply for a bike distribution quota, which is valid for three years; the government will allocate the quotas based on assessments of the companies through an open, fair, and merit-based allocation mechanism.[81] If a bike-sharing company distributes bikes without approval or in excess of its allocated quota, the government may require the company to remove the excessive bikes and pay a fine of 50,000 to 100,000 yuan.[82] The bike-sharing companies also bear the responsibility of reclaiming the bikes that are broken or non-functioning.[83] Failure to do so will lead to a fine of 50,000 to 100,000 yuan and a government seizure of such bikes.[84]

Furthermore, to satisfy the needs of users in specific time and places, bike-sharing companies shall dispatch bikes in order to alleviate the “tidal effect” — overconcentration or inadequate supply of bikes in places around busy areas during peak hours.[85] Bike-sharing companies must also send staff to patrol and coordinate in busy areas, such as public transportation hub, to ensure their bikes do not block the normal flow of traffic.[86]

c. Quality of bike-sharing services

According to the Guiding Opinions, bike-sharing companies are encouraged to use satellite positioning, big data, and information technology to strengthen the operation and administration of bikes.[87] Bike-sharing companies shall assign service teams for bike dispatching, parking, and maintenance.[88] Bike-sharing companies are encouraged to purchase personal injury insurance for customers.[89]

The proposed Shenzhen legislation further specifies that bikes distributed into bike-sharing services should install GPS locks and bear unique electronic codes.[90] Bike-sharing companies must assign maintenance teams commensurate to the number of bikes distributed to conduce maintenance work and ensure the good condition of bikes.[91] Bike-sharing companies are also encouraged to purchase personal injury insurance for customers.[92]

d. Parking of bikes

According to the Guiding Opinions, all cities shall develop technical guideline rules to establish bicycle parking lots.[93] With regard to the areas not suitable for parking, a negative list may be developed for parking prohibition.[94] In venues such as major urban business areas, public transport stations, transport hubs, residential areas, and areas surrounding tourism destinations, there will be designated bike-parking sites.[95] Bike-sharing companies that fail to clear illegal parking will be required to rectify and be fined 50,000 to 100,000 yuan.[96] The government may seize bikes if bike-sharing companies fail to rectify illegal parking.[97]

The proposed Shenzhen legislation further elaborates that transportation authority shall delineate certain restricted areas in which shared bikes must park.[98] Under this proposal, bikes cannot be parked into motor-vehicle lanes, green areas, and areas that should not be blocked, such as fire exits.[99]

e. Fees and customer deposits

According to the Guiding Opinions, fees and relevant charging rates shall be expressly disclosed to customers.[100] Bike-sharing companies are encouraged to provide rental service without deposits.[101] However, if deposits are collected from users, bike-sharing companies shall strictly separate customer deposits from their own money or customers’ advance payment.[102] Bike-sharing companies shall establish special accounts in banks for customer deposits and such accounts shall be monitored by financial and transportation government authorities to ensure deposits are used for specified purposes.[103]

The proposed Shenzhen legislation further specifies that bike-sharing companies shall expressly include the fees and charges in user service agreements.[104] Although bike-sharing companies are encouraged to provide services free from deposits, they must provide two options for the custody of customer deposits if deposits are required: the special depository accounts opened by bike-sharing companies and the individual bank settlement accounts opened by customers.[105] Customers are free to choose either of the two depository options.[106] Furthermore, under this proposal, deposits belong to customers and bike-sharing companies shall not misappropriate customer deposits.[107] With respect to interest of deposits, bike-sharing companies may stipulate the ownership of interest with customers in their service agreements.[108]

f. Unfair competition

The Guiding Opinions provides that bike-sharing companies shall not impede fair competition.[109] The proposed Shenzhen legislation further provides that bike-sharing companies shall not operate below cost or in any other way disrupt the market order for the purpose of excluding competitors or dominating the market.[110]

g. Credit management

According to the Guiding Opinions, uncivilized acts and acts in violations of laws and regulations of bike-sharing companies and users will be reflected in their credit records.[111] Bike-sharing companies shall be encouraged to form a platform to share credit information of users— establishing awarding mechanisms for users with good credits and punishing mechanisms for users with bad credits.[112]

The proposed Shenzhen legislation further requires an establishment of a credit system for bike-sharing companies and individual users.[113] Such credit information shall be included into the Shenzhen Public Credit System and be included into the national credit information sharing platform.[114] For bike-sharing companies that have bad credit scores, the government may refuse to grant approvals for operating shared bikes, impose restrictions, or include them into the highlighted monitoring list.[115]

h. Bike users’ responsibilities

The Guiding Opinions provides that users shall abide by the laws and regulations regarding road safety and urban management.[116] Bike users shall use bikes in a civilized manner, ride bikes safely, park bikes in a regulated manner, and examine the technical conditions of bikes before riding in order to ensure the safety.[117] The proposed Shenzhen legislation further provides that bike users shall not damage bikes, ride into green areas, ride into motor-vehicle lanes, or park in areas in violation of regulations.[118] In practice, many bike-sharing companies use GPS to track whether bike users park the bikes into restricted areas and may impose extra charges if this behavior occurs.

i. Data sharing platform and data privacy protection

According to the Guiding Opinions, bike-sharing companies shall submit information to local governments in a timely manner in order to allow the government to regulate based on accurate data.[119] This information includes topics such as the number of distributed bikes, distribution regions, and other operation information.[120] However, the personal information of users shall be protected and shall not be used for purposes other than providing necessary bike-sharing services.[121]

The proposed Shenzhen legislation further specifies that bike-sharing companies shall timely transmit relevant data to the government platform. [122] Relevant data includes the dynamics of the total number of bikes, their locations, parking spaces, information about customer orders, tracks of bikes, and information from maintenance teams.[123] Data privacy shall be protected according to relevant data privacy laws.[124]

   VI. Conclusion

The bike-sharing industry in China has experienced a boom and corresponding bust since 2017. While providing an environmental-friendly way to commute, the flawed capital-driven business model also brought the bicycle graveyards to the cities. After the rapid and disorderly expansion of the bike-sharing market, the Chinese government established national and local guidelines in order to balance the need for shared bikes and the need for reducing the negative effects caused by bike sharing. However, the guidelines do not have binding effect and regulations are better to be implemented through legislation. Given the amount of attention of the government, it is optimistic that bike sharing is becoming more regulated and would truly serve the goal of the sharing economy.

[1] See Guiding Opinions on Encouraging and Regulating the Development of Internet Bicycle Rental (关于鼓励和规范互联网租赁自行车发展的指导意见), GOV (Aug. 3, 2019, 8:25 AM), www.gov.cn/xinwen/2017-08/03/content_5215640.htm;

[2]See The 41^st Statistical Report on Internet Development in China (第41次《中国互联网络发展状况统计报告》), Cyberspace Administration of China (Jan. 31, 2018, 2:00 PM), http://www.cac.gov.cn/2018-01/31/c_1122347026.htm.

[3] The “last mile” issue refers to the last mile between the public transportation and the destination, e.g. a walking distance between a subway station to a person’s office building. See supra note 1; supra note 2.

[4] Guoyong Wu (吴国勇), No Place to Place (无处安放), QQ (July 26, 2018), http://v.qq.com/x/page/c0734zu8r4p.html.

[5] See Kun He (何困), Ofo Team: Cycling + Internet = Hobby + Business ( ofo团队: 骑行+互联网=爱好+事业), Univs (Mar. 7, 2016), http://special.univs.cn/service/pku/pkuyanxing/2016/0307/1127798.shtml.

[6] See id.

[7] See Ofo Little Yellow Bike (ofo小黄车), Baidu, https://baike.baidu.com/item/ofo%E5%B0%8F%E9%BB%84%E8%BD%A6/20808277?fromtitle=ofo&fromid=20104243&fr=aladdin (last visited Jan. 17, 2020).

[8] See Mobike (摩拜单车), Baidu, https://baike.baidu.com/item/%E6%91%A9%E6%8B%9C%E5%8D%95%E8%BD%A6/19737256?fromtitle=%E6%91%A9%E6%8B%9C&fromid=20590655&fr=aladdin (last visited Jan. 17, 2020).

[9] See Nearly 30 Companies Competing in Bike Sharing, There Would be a Shuffle after the Winter (近30家厂商逐鹿共享单车 冬天过后将洗牌), Sina (Jan. 6, 2017, 3:13 AM), https://tech.sina.com.cn/i/2017-01-06/doc-ifxzkfuh5593018.shtml.

[10] See supra note 2.

[11] See Interpretation of the Guiding Opinions on Encouraging and Regulating the Development of Internet Bicycle Rental by Yahua Xu, the Director of the Transportation Service Department of the Ministry of Transportation (交通运输部运输服务司司长徐亚华解读《关于鼓励和规范互联网租赁自行车发展的指导意见》), GOV (Aug. 4, 2017, 4:05 PM), www.gov.cn/xinwen/2017-08/04/content_5215971.htm.

[12] See supra note 2.

[13] See id.

[14] See id.

[15] See id.

[16] See id.

[17] See The 42^nd Statistical Report on Internet Development in China (第42次《中国互联网络发展状况统计报告》), Cyberspace Administration of China (Aug. 20, 2018, 3:21 PM),  http://www.cac.gov.cn/2018-08/20/c_1123296882.htm.

[18] See Twelve Cities Stopped the Increase of Shared Bikes, Share Bikes Started to Turn to Overseas Markets (全国12城市叫停新增投放 共享单车开始骑向海外), Sina (Dec. 20, 2017, 11:56 AM), finance.sina.com.cn/chanjing/cyxw/2017-12-20/doc-ifypxmsq8384670.shtml.

[19] See supra note 17.

[20] See id.

[21] See Shared Bikes Should be Free from Deposits (共享单车应该免押), Baidu (Mar.18, 2018, 12:44 PM), https://baijiahao.baidu.com/s?id=1595249240416216665&wfr=spider&for=pc.

[22] See supra note 17.

[23] See supra note 7.

[24] See id.

[25] See id.

[26] See supra note 2.

[27] See id.

[28] See supra note 18.

[29] See id.

[30] See Shanghai Issued the Strictest Restriction on Share Bikes, Prohibiting New Distribution of Shared Bikes (上海最严共享单车限制令出台 禁止新增投放共享单车), SH.Bendibao (Aug. 21, 2017, 11:56 AM), sh.bendibao.com/news/2017821/184671.shtm.

[31] See supra note 18.

[32] See Ji Lin (林桔) & Fangge Zhan ( 詹方歌), Destination of the Disappeared Shared Bikes Other Than Bicycle Graveyards (消失的共享单车 “坟场”以外的归宿), Baidu (Sept. 2, 2019, 9:47 AM), https://baijiahao.baidu.com/s?id=1643527017081122239&wfr=spider&for=pc.

[33] See id.

[34] See id.

[35] See id.

[36] See id.

[37] See Why the Government Suddenly Prohibited Shared Bike Distribution? (为什么政府突然禁止共享单车的投放?), Sohu (Sept. 11, 2017, 6:21 PM), https://www.sohu.com/a/191241781_99994191.

[38] See id.

[39] See id.

[40] See Jing Wen (温婧), Increase of Price by All Shared Bikes: When Capitals Retreats and Companies Need to Profit, Would You Continue to Ride Bikes? (共享单车齐涨价：资本撤离后企业亟需盈利 你还骑吗?), People (Apr. 9, 2019, 8:17 AM), it.people.com.cn/big5/n1/2019/0409/c1009-31019115.html.

[41] See id.

[42] See id; see also Mobike and ofo Cancelled Monthly Card Benefits, Bike-Sharing Companies Started Harvesting Users (摩拜和ofo取消月卡优惠, 共享单车开始收割用户), Sina (Mar. 2, 2018, 9:06 AM), https://tech.sina.com.cn/i/2018-03-02/doc-ifwnpcnt0033390.shtml.

[43] See Wen, supra note 40.

[44] See How Did ofo Little Yellow Bike Come into Today’s Situation Step by Step (ofo小黄车是如何一步步走到今天的局面的?), Baidu (Mar. 6, 2019, 12:51 PM), https://baijiahao.baidu.com/s?id=1627230464063151451&wfr=spider&for=pc.

[45] See supra note 7.

[46] See supra note 2.

[47] See Mobike Promotions Five Yuan for Three Months and Free for Two Months (摩拜单车月卡3个活动 5元购买3个月摩拜单车月卡 免费领2个月), Iqshw (July 21, 2017, 6:47 PM), https://www.iqshw.com/qita/131459.html.

[48] See Ofo Introduced 1 Yuan Pass for 30 Days (ofo推出1元包月卡 可骑行30), Sina (Aug. 16, 2017, 10:57 AM), https://tech.sina.com.cn/i/2017-08-16/doc-ifyixtym5657094.shtml.

[49] See Wen, supra note 40.

[50] See id.

[51] See Li Xu (徐立), How Does Bike-Sharing Industry Make Money? You Will Know After Reading This (共享单车靠什么赚钱？看完你就彻底明白了！), Sohu (Feb. 22, 2018, 8:17 AM), https://www.sohu.com/a/132506825_393543.

[52] See id.

[53] See id.

[54] See id.

[55] See id.

[56] See Xu, supra note 51.

[57] See Benefits of Shared Bikes: Hellobike Started to Offer Free Deposits Nationwide (共享单车重磅福利：哈罗开启全国免押), Baidu (Mar. 11, 2018, 9:56 AM), https://baijiahao.baidu.com/s?id=1594604453257635342&wfr=spider&for=pc.

[58] See id.

[59] Ministry of Ministry of Transport Solicits Public Comments on Bike Sharing Development,

Expert: The Government Must Do More (交通部就共享单车发展公开征求意见, 专家: 政府须有更多作为), Haiwainet (May 22, 2017, 8:33 AM), m.haiwainet.cn/middle/352345/2017/0522/content_30925811_1.html.

[60] See supra note 18; supra note 30.

[61] See supra note 18; supra note 30.

[62] See Lin & Zhan, supra note 32.

[63] See supra note 59.

[64] See id.

[65] See Guiding Opinions on Encouraging and Regulating the Development of Internet Bicycle Rental (关于鼓励和规范互联网租赁自行车发展的指导意见), GOV (Aug. 3, 2019, 8:25 AM), www.gov.cn/xinwen/2017-08/03/content_5215640.htm.

[66] See Interpretation of the Guiding Opinions on Encouraging and Regulating the Development of Internet Bicycle Rental by Yahua Xu, the Director of the Transportation Service Department of the Ministry of Transportation (交通运输部运输服务司司长徐亚华解读《关于鼓励和规范互联网租赁自行车发展的指导意见》), GOV (Aug. 4, 2017, 4:05 PM), www.gov.cn/xinwen/2017-08/04/content_5215971.htm.

[67] See supra note 65.

[68] See id.

[69] See id.

[70] See id.

[71] See Guiding Opinions on Encouraging and Regulating the Development of Internet Bicycle Rental in Shanghai (Trial) (上海市鼓励和规范互联网租赁自行车发展的指导意见（试行）), Shanghai.Gov (Nov. 9, 2017), http://www.shanghai.gov.cn/nw2/nw2314/nw2319/nw12344/u26aw54099.html.

[72] See Guiding Opinions on Encouraging and Regulating the Development of Internet Bicycle Rental in Guangzhou (关于鼓励和规范广州市互联网租赁自行车发展的指导意见), GZ.Gov (Jan 3, 2018), http://www.gz.gov.cn/gzswjk/2.2.23/201801/e1fb92639e92435eb1d4164c9a6d4f09.shtml;

[73] See Announcement of Shenzhen Judicial Department Regarding Legislation on Internet Bicycle Rental (Draft for Comments) (深圳市司法局关于公开征求互联网租赁自行车管理立法（征求意见稿）意见的通告), SZ.GOV, (Aug. 1, 2019), http://sf.sz.gov.cn/xxgk/xxgkml/gsgg/201908/t20190801_18103855.htm.

[74] See supra note 65, art. 5.

[75] See id.

[76]See Interim Regulation on Internet Bicycle Rental Services (Draft for Comments) (深圳市互联网租赁自行车经营服务管理暂行办法（征求意见稿）), art. 6, 7, SZ.GOV (Aug. 1, 2019), http://sf.sz.gov.cn/xxgk/xxgkml/gsgg/201908/P020190801637153603305.doc.

[77] See supra note 65, art. 4.

[78] See id.

[79] See id.

[80] See supra note 76, art 5, 10.

[81] See id., art. 9, 11.

[82] See Several Regulations on the Development of Internet Bicycle Rental Business (Draft for Comments) (深圳经济特区互联网租赁自行车发展若干规定（征求意见稿）), art. 9, SZ.GOV (Aug. 1, 2019), http://sf.sz.gov.cn/xxgk/xxgkml/gsgg/201908/P020190801637153418325.doc.

[83] See id. art. 11.

[84] See id.

[85] See supra note 76, art. 19.

[86] See id.

[87] See supra note 65, art. 8.

[88] See id.

[89] See id.

[90] See supra note 76, art. 13.

[91] See id., art. 17.

[92] See id., art. 16.

[93] See supra note 65, art. 6.

[94] See id.

[95] See id.

[96] See supra note 82, art. 10.

[97] See id.

[98] See supra note 76, art. 18.

[99] See id.

[100] See supra note 65, art. 8.

[101] See id., art. 12.

[102] See id.

[103] See id.

[104] See supra note 76, art. 26.

[105] See id., art. 24.

[106] See id.

[107] See id.

[108] See id.

[109] See supra note 65, art. 16.

[110] See supra note 76, art. 26.

[111] See supra note 65, art. 11.

[112] See id.

[113] See supra note 76, art. 32.

[114] See id.

[115] See id.

[116] See supra note 65, art. 10.

[117] See id.

[118] See supra note 76, art. 29.

[119] See supra note 65, art. 8.

[120] See id.

[121] See id., art. 13.

[122] See supra note 76, art. 20.

[123] See id.

[124] See id., art. 27.