The findings reveal that PRC’s gray-zone strategy demonstrates a dual interdependence. Firstly, in the “legal domain”, by selectively interpreting the United Nations Convention on the Law of the Sea (UNCLOS) to expand coastal state jurisdiction and enacting ambiguous domestic statutes and judicial rulings to construct a legal basis favorable to its position. Secondly, in the “international relations domain”, by reinforcing jurisdictional claims through persistent exercises and enforcement actions. Three key features characterize this strategy: (1) Asymmetry– whereby PRC avoids direct confrontation with the United States by reshaping international law to its advantage; (2) Ambiguity– by promulgating domestic laws that challenge the status quo without overtly violating international norms; (3) Incrementalism– by legitimizing domestic jurisdiction through continuous state practice. The paper concludes by recommending that the United States should sustain freedom of navigation operations and strengthen U.S.-Taiwan maritime cooperation to uphold a rulesbased maritime order, while Taiwan should continue clarifying and countering PRC’s claims, cultivate expertise in international law, improve the rules of engagement, and bolster both legal and societal resilience against gray-zone

challenges.