Ban TikTok on national security grounds

Research notes

• The ban the Mandate asked for never happened; the Administration kept TikTok running through four successive non-enforcement orders and then approved a divestiture under the Act’s qualified-divestiture path. We record it as not started throughout, with the divestiture noted, because the ask is a ban and the outcome is the app’s continued operation. A reviewer could read the 2026-01-22 divestiture as partial (the statute’s national-security remedy applied without a ban); see the Chapter 28 log’s Judgment calls.
• No White House or Justice Department page on the January 2026 closing was found in the Corpus (presidential-actions.ndjson has nothing on TikTok after 2025-09-25), so the closing rests on the AP report carried by NPR. The joint venture’s own announcement (newsroom.tiktok.com) is off the allowlist — a lead.
• The Protecting Americans from Foreign Adversary Controlled Applications Act (Pub. L. 118-50, div. H) and TikTok Inc. v. Garland (Supreme Court, 2025-01-17) predate the tracking window and are context, not Evidence.

Resolved in review (2026-10-16): see the 2026-07-16 event. The 2026-09-30 CourtListener opinions snapshot carries an Office of Legal Counsel opinion, Application of the No TikTok on Government Devices Act to the TikTok USDS Joint Venture (50 Op. O.L.C. __, 2026-07-16, T. Elliot Gaiser, to the Deputy Counsel to the President). Its Corpus full text concludes that “TikTok USDS is not banned from federal government devices by the No TikTok on Government Devices Act”, because ByteDance is a minority shareholder without voting power over the joint venture’s security protocols. It also memorializes earlier advice of 2026-02-03 and 2026-03-10, and records that the Deputy Counsel “instructed that employees of Executive Branch agencies may download TikTok onto their official devices, subject to the agency’s discretion”. That would undo the one federal TikTok restriction left in force, so it runs further against the ask. It is not a rung, and the Status stays not started. The opinion was read from the Corpus only, so it is not yet Evidence (playbook §6). To close: open https://www.justice.gov/olc/media/1453136/dl (CourtListener opinion/10932591). If the text matches, add a not started event dated 2026-07-16 citing it. Also look for the White House instruction it describes: is there a dated OMB or Counsel memorandum lifting the device ban?

Review (2026-10-16, network). The opinion was opened at justice.gov/olc/media/1453136/dl (12 pages); its syllabus and first page match the Corpus text, and the 2026-07-16 event cites it. The instruction it describes is not public: no OMB memorandum rescinding the 2023 implementation guidance (M-23-13) and no FAR change to the ByteDance covered-application clause (52.204-27) is in the Federal Register or presidential-actions Corpus through 2026-10-15. Look again if either appears.