The New York Times reported on 7 November (The New York Times) that a Chinese company called New Matrix, which the Commerce Department approved this year to assemble Nvidia’s H200 chips into AI servers, lists an address that stands empty. A Times reporter found the office in an industrial park on the northwest fringe of Beijing to be “a hollow gray shell with wires dangling from the ceiling where lights should be”.
New Matrix is the second Chinese company approved to handle Nvidia’s H200 chips that does not seem to have any physical presence at its listed address, the Times reported. In September the paper found the listed office of another approved firm, Maginfra, apparently deserted.
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The key insight: The New York Times found two Commerce-cleared H200 licensees with no apparent office at their listed addresses, out of roughly two dozen firms approved, per people familiar with the approvals; the Bureau of Industry and Security said it carefully reviews all applications.
According to Chinese corporate records, New Matrix’s owners have ties to Wise Road, a Chinese private equity fund the US government placed on its entity list in 2024, the Times reported. Two analysts who examined the records said they believed New Matrix may be a front for firms associated with that fund. New Matrix was created 17 months ago and did not respond to requests for comment, per the report.
Analysts told the Times they believed Maginfra was an offshoot of Inspur, a company on the entity list for working with the Chinese military. The paper also reported that two other licensees, Zhejiang Yindun Cloud Technology and Shanghai Jiatang, have ties through their owners to firms that serve the Chinese military. Maginfra, Yindun Cloud and Shanghai Jiatang did not respond to requests for comment.
Chinese firms cleared to buy or handle Nvidia H200 chips, per The New York Times: roughly two dozen approved (per people familiar), four licensees the Times named with blacklist or military ties, and two with no apparent office at their listed address. Counts of named firms: our count.
How Many Firms Were Cleared
In total, the Commerce Department appears to have approved roughly two dozen Chinese firms to buy or handle Nvidia’s H200 chips, including Baidu, BYD and Tesla Shanghai, the Times reported, citing people familiar with the approvals. The firms received approval to purchase tens of thousands of the chips each but have not yet met that quota, the people said.
By our count, two of those roughly two dozen firms, New Matrix and Maginfra, had no apparent physical presence at their listed addresses when Times reporters visited: about one in twelve. That share rests on the Times’s approximate total.
What Washington and Nvidia Said
A spokesman for the Bureau of Industry and Security said it carefully reviews all applications for national security risks, the Times reported. The agency said it had imposed $324 million of penalties on companies for export violations in 2025 and hired more than 90 officers this year to enforce technology rules.
Nvidia spokesman John Rizzo said that “it makes no sense for the Chinese military to depend on American technology”, per the report. Liza Tobin, a former China director for the White House National Security Council, told the Times: “I have a ton of concerns that neither the Commerce Department or Nvidia is doing the due diligence needed to ensure that the licensing terms are being followed”.
Why the H200 Matters
President Trump allowed H200 sales to China in December, as long as the US government received a cut, with the chips routed through the United States so that a 25 percent tariff can be collected, the Times reported. In the quarter that ended in July, H200 shipments to customers based in China made up less than 1 percent of Nvidia’s data center revenue, per the report. Our timeline of Nvidia’s export rules and probes in China is here.
The report adds to scrutiny of Nvidia’s China sales this week: the FT reported a US memo alleging ties between chief executive Jensen Huang and a suspected Chinese spy (our piece), following the Times’s 29 October report (our piece), and three House chairs have asked Huang to brief them on 18 November (our piece).
The Structural Read
As we read the report, the finding is about the licensing check: New Matrix and Maginfra were approved to assemble H200 chips into servers, not as the final buyers, per the Times.
As we read it, the front-company view comes from analysts the Times consulted; the report does not establish who controls New Matrix.
As we read the numbers, two of roughly two dozen approved firms is about one in twelve, by our count, and rests on an approximate total.
Liza Tobin, former China director, White House National Security Council, to The New York Times
“I have a ton of concerns that neither the Commerce Department or Nvidia is doing the due diligence needed to ensure that the licensing terms are being followed”
Three Implications
FOR THE LICENSING REVIEW The Bureau of Industry and Security said it carefully reviews all applications and imposed $324 million of penalties for export violations in 2025, per the Times.
FOR NVIDIA H200 shipments to China were under 1 percent of Nvidia’s data center revenue in the quarter that ended in July, per the Times.
FOR THE HOUSE BRIEFING Three committee chairs have asked Jensen Huang to brief them on 18 November, per our earlier piece.
The analysis says: “It’s a fundamental constraint on the speed of AI transformation, and it’s creating geopolitical leverage that operates independently of who has the best models.”
As we read it, export licensing for Nvidia chips is one form of that leverage; the analysis does not discuss New Matrix, Maginfra or this report.
What Is Not Established
The Times did not report who ultimately controls New Matrix; the front-company view is that of two analysts it consulted. The full list of licensees has not been published, and the roughly two dozen total comes from people familiar with the approvals. No charges or licence revocations have been reported.
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The New York Times found that New Matrix, a firm the Commerce Department cleared to assemble Nvidia’s H200 chips, lists an empty office and has owners tied to a blacklisted fund, the second such licensee after Maginfra. The Bureau of Industry and Security said it carefully reviews all applications; Nvidia said Chinese military reliance on American technology makes no sense.
A note on sourcing. The findings are those of The New York Times, based on reporters’ visits, Chinese corporate records and people familiar with the approvals; the front-company view is that of analysts the Times consulted. Counts of named firms are ours.
Gennaro Cuofano is a CRO and tech executive who has worked in AI since late 2015, starting with bringing NLP, natural-language generation, voice and chatbot products to the marketing industry. His background is in law and finance: he holds a Master's degree in Law and an International MBA with an emphasis on corporate finance (LUISS Business School and the University of San Diego, 2012), and worked as a financial analyst at a real-estate investment firm in San Diego and as an assistant controller. His work focuses on business model strategy, business engineering and, more broadly, structural analysis: how companies make money, read from their own filings. He created FourWeekMBA and leads research there and at The Business Engineer, his newsletter on AI and business strategy, with over 95,000 subscribers and more than 1,000 published analyses. His writing has also appeared on Entrepreneur (for example, How to Digitize a Family Business in Europe) and HackerNoon. Find him on LinkedIn and Substack. See how we source.
