Fabless semiconductor company Triductor Technology (Suzhou) Inc. is a supplier of chips to companies on the Department of Commerce Entity list, including Huawei, and utilizes U.S.-origin tools to design its chips, Kharon has found. 

The Company. Triductor Technology, founded in 2006, designs and manufactures chips used in telecommunication equipment. It was successfully listed on the Shanghai Stock Exchange in January, with a market capitalization of approximately $6.14 billion yuan ($936 million USD) as of April 26, 2022. Triductor Technology disclosed to investors that the company procures and uses U.S.-origin software and layout IP licensed from American companies to design its chips. 

Sales to Entity List Companies, Including Huawei. Triductor Technology has supplied chips to companies on the Department of Commerce Entity List.

• Huawei, added to the Department of Commerce’s Entity List in 2019, appears to be mentioned in Triductor Technology’s IPO prospectus under the moniker of “Company A.” According to the prospectus, “Company A” previously held a stake in Triductor Technology but divested in 2017, and records reviewed by Kharon show that Huawei divested from Triductor Technology in 2017. The prospectus describes “Company A” as the “world’s leading provider of telecommunications infrastructure” and states that recent export control measures implemented by the U.S. government “generated adverse effects on Company A.” “Company A” accounted for as much as 53% of Triductor Technology’s total sales in recent years.
  
  
• Huawei was named as a partner of Triductor Technology and a user of its products in press releases, job postings, and social media posts prior to 2020. However, Triductor Technology has since removed some online references to its relationship with Huawei.
   
• Fiberhome Technologies Group is a Chinese telecommunication equipment provider that the Department of Commerce added to the Entity List in June 2020 for its involvement in high-technology surveillance and repression of Uyghurs and other ethnic minorities in China’s Xinjiang region. Fiberhome is one of the “primary end users” of Triductor’s networking chips, according to the IPO prospectus.