Recently, the Supreme People's Court issued the typical cases on serving and safeguarding the construction of pilot free trade zones by people's courts. A case of dispute over confirmation of shareholder qualifications (Carson v. Niuxinda Company) tried by Shanghai First Intermediate People's Court, i.e. China's first case where an overseas natural person requested shareholder qualification confirmation after the implementation of the Foreign Investment Law, was selected. The case was presided over by Zheng Tianyi, former Director of the Research Office of Shanghai First Intermediate People's Court (now Director of the Research Office of Shanghai High People's Court), with Cheng Yang and Ao Yingjie as members of the collegial panel. Carson, a citizen of the United States, agreed with Zhang A and Cheng A (each with partial name withheld), Chinese citizens, to form a trading company in China. As the then Chinese law disallowed a foreign natural person to establish a joint venture with a domestic natural person, the three persons signed a Share Agreement, agreeing to form Niuxinda Company in the names of Zhang A and Cheng A. Carson later sued, claiming a confirmation that part of equities in Niuxinda Company in the name of Zhang A was owned by him and that Niuxinda Company should cooperate in making such modifications as to register the part of equities under the name of Carson. After the trial, Pudong New Area People's Court of Shanghai held that Carson was a dormant shareholder of Niuxinda Company and Zhang owned 26% of the Company's equity on behalf of Carson. According to Chinese laws, despite a citizen of the United States, Carson's behavior of establishing a company jointly with Zhang and Cheng was still valid and Niuxinda's business scope did not fall within the negative list. There was no legal barrier to change Carson's registration as Niuxinda Company's shareholder. Hence, Carson's claim was supported. Niuxinda Company filed an appeal against the judgment. Shanghai First Intermediate People's Court held upon trial that according to the contents of the Share Agreement, all parties concerned acknowledged that Carson owned 51% of Niuxinda Company's equity. According to the Capital Contribution Certificate, authenticity of which was confirmed after appraisal, Carson was a shareholder of Niuxinda Company and had made his capital contribution. In addition, it could be confirmed from the form and content that Zhang communicated with Carson via email and Carson was actually involved in the Company's operation. Therefore, the judgment of first instance was correct and upheld.