Two crucial differences: 1) Chinese law can be used to coerce indivudusls (including presumably tech company execs) to spy for the state. That is illegal under US law. And uf you're a Chinese student abroad, good luck saying no to the Public Security tity Office when asked to spy on other students.

2) US law, however evilly applied, requires a modicum of specificity and a fig leaf of justification. China law has no such need and can appropriate at scale to its bureaucratic desire (e.g, all IP addresses in Washington, D.C.)