关键词: 数据垄断, 数据治理模式, 数据主权, 数据权益, 数据市场, 数字经济

Abstract: Data monopoly threatens national data sovereignty, digital economy development and individual data rights, and it is significant to construct a scientific and reasonable data monopoly governance model. In this paper, we have obtained the relevant theories, European and American regulations, organizations and enforcement cases through online and literature research, and summarized the respective antitrust analysis models of them. Based on the analysis models and their application characteristics, this paper analyzes the prudent regulation model of the United States, which focuses on the process of behavior, and the tight control model of the European Union, which focuses on the review of the effects of the purpose, further analyzes and draws on their advantages, disadvantages and experiences, and proposes countermeasures for the construction of data monopoly governance model in line with China's actual situation. This will help China maintain data sovereignty and security, protect data rights and interests, and achieve healthy development of digital economy.

Key words: Data monopoly, Data governance model, Data sovereignty, Data right, Data market, Digital economy