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35 TOK Exhibition Prompts: The Complete List Updated

by  Antony W

January 4, 2024

The Theory of Knowledge Exhibition is a new assessment in the TOK syllabus. It replaces the TOK presentation and account for a third of the total marks for the TOK.

Assessed internally and moderated externally, the aim of the assessment is to help students demonstrate how Theory of Knowledge concepts manifest in the real world.

In addition to identifying the 3 objects for the exhibition , students have to choose one IA prompt from the 35 topics and then show the link between the selected objects and the IA prompt in a 950-word commentary .

In this lesson, you’ll learn how to choose the best IA prompt for your TOK exhibition so that you can have an easy time exploring your objects and writing the commentary.

What Are TOK Exhibition Prompts in IA?

The TOK exhibition prompts in IA are open questions a student has to explore in their commentary.

It’s important to note that ToK essay titles are different from IA prompts in the sense that while essay titles are subject to change, IA prompt remains the same each year.

In the context of the Theory of Knowledge exhibition, the IA prompt you choose should link back to the 3 objects and use context of either the core theme or one of the optional themes to how TOK manifests itself in the real world.

The IA prompt you choose will determine the design and methodology you use to use to arrive at your interpretation of the objects or the images of the objects that you choose for the exhibition.

How to Choose The Best IA Prompt for Your TOK Exhibition

According to the TOK exhibition guide, you have to choose only one question from the 35 IA topics. Yet given that 35 means a lot of option, it’s easy to get lost in a world of possibilities . 

However, if you apply the right filter to each prompt, you’ll not only understand them better but also find an IA prompt that you can explore within the context of the core theme or one of the optional themes in TOK.

1. Reading Each Prompt

Reading the 35 IA prompts one at a time can be time consuming, but that’s the only best way to know the concept behind each question as it relates to the Theory of Knowledge.

Some aspects will link to just one prompt and some may have a closer link to several of the 35 IA prompts. 

2. Picking a Prompt

Once you have a clear concept of the IA prompts, look at them once again and then identify what would work best for you.

It’s best to choose a prompt that interests you or one that has a concept that you already find interesting enough to explore.

If a prompt resonates with your experiences in and outside school, go with it.

3. Relating Your IA Prompt to a Theme

The IB TOK guide requires that you set your exhibition within the context of one of the optional themes or the core theme.

So it’s important to make sure that the IA prompt that you choose is one that you can easily relate to the themes.

You can take this even further and explore the IA prompt in relation to real life situations .

Doing so will go a long way to give you a clear idea about the objects to choose and what your exhibition should be about.

TOK Exhibition Prompts List

1. What counts as knowledge?

2. Are some types of knowledge more useful than others?

3. What features of knowledge have an impact on its reliability?

4. On what grounds might we doubt a claim?

5. What counts as good evidence for a claim?

6. How does the way that we organize or classify knowledge affect what we know?

7. What are the implications of having, or not having, knowledge?

8. To what extent is certainty attainable?

9. Are some types of knowledge less open to interpretation than others?

10. What challenges are raised by the dissemination and/or communication of knowledge?

11. Can new knowledge change established values or beliefs?

12. Is bias inevitable in the production of knowledge?

13. How can we know that current knowledge is an improvement upon past knowledge?

14. Does some knowledge belong only to particular communities of knowers?

15. What constraints are there on the pursuit of knowledge?

16. Should some knowledge not be sought on ethical grounds?

17. Why do we seek knowledge?

18. Are some things unknowable?

19. What counts as a good justification for a claim?

20. What is the relationship between personal experience and knowledge?

21. What is the relationship between knowledge and culture?

22. What role do experts play in influencing our consumption or acquisition of knowledge?

23. How important are material tools in the production or acquisition of knowledge?

24. How might the context in which knowledge is presented influence whether it is accepted or rejected?

25. How can we distinguish between knowledge, belief and opinion?

26. Does our knowledge depend on our interactions with other knowers?

27. Does all knowledge impose ethical obligations on those who know it?

28. To what extent is objectivity possible in the production or acquisition of knowledge?

29. Who owns knowledge?

30. What role does imagination play in producing knowledge about the world?

31. How can we judge when evidence is adequate?

32. What makes a good explanation?

33. How is current knowledge shaped by its historical development?

34. In what ways do our values affect our acquisition of knowledge?

35. In what ways do values affect the production of knowledge?

Frequently Asked Questions

1. are there more than 35 prompts.

No, there are only 35 IA prompts for the exhibition and you cannot add to the list. Your teacher expects you to choose only one prompt from the list and relate it to all the three objects.

2. Can I Change the Wording a Prompt?

The IB TOK guide states explicitly that you should not reword any title (question) provided in the prompt. Use them exactly as prescribed.

3. Where Can I Find the Prompts?

Check page 40 to 41 of the ToK syllabus guide. If you don’t have access to the guide, ask your teacher to share a copy with you. Or you can ask them to share only a list of the IA prompts in a separate document.

4. What’s the Right Way to Link the Prompt to the ToK Course?

The new assessment requires you to explore your Internal Assessment prompt within the context of one of the core themes (language, technology, indigenous societies, religion, and politics) or the core theme (knowledge and the knower).

Therefore, the best way to relate your IA prompt to the TOK course is to think of it in terms of either of the two themes.

5. Can You Help Me Write the Exhibition?

You can hire an exhibition writer on Help for Assessment to complete the project for you. Our experts will help you every step of the way to get the assignment completed in time.

What makes our service different from the other similar companies online is our systematic approach to the assignment.

We search for a suitable prompt for your assignment. We then identify an appropriate theme for the prompt and choose 3 related objects.

Our research process follows where we explore the most relevant information that not only best describes these objects but also demonstrate their real-world context.

Our experts even create an outline suitable for the commentary, making sure we compress each section within the expected word limit. We then use the right format to write a comprehensive commentary that how the TOK exhibition manifests itself in the real world.

3. Can You Complete a ToK Essay for Me?

We've helped many students to complete their ToK essays on time.

So if you're struggling with the same, you can order ToK essay online on our platform and one of our experts will help you complete the task in good time. 

About the author 

Antony W is a professional writer and coach at Help for Assessment. He spends countless hours every day researching and writing great content filled with expert advice on how to write engaging essays, research papers, and assignments.

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ToK Essay Prompts Demystified: Interpreting and Tackling 2023's Questions

Navigating the complex web of ToK essay prompts can feel like trying to decipher an ancient manuscript – it's challenging, yet deeply rewarding. Every year, the IB presents students with fresh, thought-provoking questions that aren’t just about showcasing your knowledge but also your ability to reason, reflect, and engage in intellectual play.

Now, 2023's prompts have landed, and you might be wondering: "How do I even begin to approach these?" Relax. It's normal to feel overwhelmed. However, understanding your prompt is the first (and perhaps most crucial) step towards crafting an essay that stands out. A well-interpreted prompt can be the foundation of a stellar essay, and that's what we're diving into today.

By the end of this guide, you’ll have a clearer vision of what these questions are really asking and how you can tackle them with confidence and creativity. Ready? Let’s demystify these prompts together!

The ABCs of ToK Essay Prompts

Understanding ToK essay prompts isn't just about reading the words. It's about delving deep into their meaning, intent, and the broader context they inhabit. Think of each prompt as a puzzle. At first glance, it might seem daunting, but each piece holds a clue to the bigger picture.

Why These Questions? The Intent Behind the Prompt

Every ToK essay prompt is meticulously crafted. The questions are designed to push you to reflect, reason, and develop an individual perspective on knowledge and how it interacts with the world. Remember, it's not just about answering the question but also about showcasing how you think and perceive the world of knowledge.

The Layers of a Prompt: Surface and Depth

On the surface, a ToK essay question may seem straightforward. But scratch a little deeper, and you'll uncover layers of meaning. Each prompt comes with its set of nuances, undertones, and subtleties. It's your job to unearth these layers, interpret them, and mold your essay around your unique understanding.

Flexing Your Interpretative Muscles

Interpreting a ToK prompt isn't much different from analyzing a poem or a piece of art. There's no singular 'correct' way to approach it. Multiple interpretations can coexist, and your perspective is just as valid as any other, provided it's well-reasoned and backed by thoughtful reflection. Remember, the IB isn't looking for a 'right answer' but rather, they want to witness the journey of your thought process.

2023's ToK Essay Prompts: A Closer Look

Alright, champions of knowledge! The much-awaited 2023 ToK essay questions are here. Let's unpack these thought-provoking challenges that await your intellectual prowess:

The Role of Replicability : Is replicability necessary in the production of knowledge? Dive into the depths of this question, referencing two areas of knowledge and unveiling the significance of reproducibility in our understanding of the world.

Artists vs. Natural Scientists : For artists and natural scientists, which is more crucial: what can be explained or what cannot be? Delve into the contrasting yet intertwined worlds of arts and the natural sciences. How do explanation and mystery influence these fields?

Knowledge in Bubbles : Does it matter if our acquisition of knowledge happens in "bubbles" where some information and voices are excluded? Explore the implications and consequences of receiving knowledge in isolated silos. What do we gain, and what might we be missing out on?

The Paradox of Power : Do you agree with Bertrand Russell's assertion that it is "astonishing that so little knowledge can give us so much power"? Dive into the dynamic realm of the natural sciences and another area of knowledge to reflect upon the immense power that even a sliver of understanding can bestow upon us.

The Visual Aid Dilemma : Are visual representations always helpful in the communication of knowledge? Challenge or defend the use of visuals in the expansive territories of the human sciences and mathematics. How do visuals shape, aid, or potentially hinder our understanding?

Methodologies and Outcomes : To what extent is the knowledge we produce determined by the methodologies we use? Take a journey through history and another area of knowledge to discern the profound influence of methodologies on our comprehension of the past and the world around us.

Phew! Talk about a brainstorming marathon! Remember, while these prompts may initially seem dense, each one is a golden opportunity to showcase your unique perspective on knowledge. The journey might be challenging, but the rewards – oh, they're worth every ounce of effort.

Delving Deeper into Select Prompts

While all of the 2023 ToK essay prompts are a treasure trove of intellectual exploration, let's zoom in and dissect a few of them a bit more, shall we? This deep dive will provide a clearer understanding, perhaps sparking that ‘aha’ moment for your own essay.

The Role of Replicability in Knowledge Production

Overview : This topic challenges us to reflect on the importance of replicability in research and knowledge generation. But why is it significant? Think of scientific experiments. If a result can be consistently replicated, it bolsters its credibility.

Possible Angle : Contrast the natural sciences, where replicability is often a cornerstone, with another area of knowledge where it might not hold as much weight. For instance, in the arts, is a replicated piece as valuable as an original?

Knowledge in Bubbles - A Double-Edged Sword?

Overview : The modern age, with its vast array of information platforms, often sees us in echo chambers, where we hear opinions and facts that align with our own views. But what's the consequence of such selective knowledge acquisition?

Possible Angle : Evaluate the pros and cons. For instance, while these bubbles can strengthen community ties and provide tailored knowledge, are they also breeding grounds for misinformation or limiting broader understanding?

The Paradox of Power in Knowledge

Overview : Bertrand Russell's assertion highlights a profound observation – sometimes, even a little knowledge can yield immense power. But is this always a good thing?

Possible Angle : Reflect on historical instances where limited knowledge led to significant consequences, both positive and negative. Additionally, ponder on the ethical implications when wielding such power.

Remember, these prompts are meant to stimulate your thinking, not restrict it. Let your creativity flow. Dive deep, challenge assumptions, and most importantly, enjoy the intellectual journey. If at any point you find yourself hitting a roadblock, revisit our previous guide on mastering the ToK essay for some inspiration and direction.

General Strategies for Approaching ToK Essay Prompts

Alright, young scholars, having taken a closer look at a few of the prompts, it’s time to arm you with some universal strategies to tackle any ToK essay topic. Whether you’re addressing the role of replicability or diving into knowledge bubbles, these strategies are your trusted companions:

Begin with an Open Mind : Before taking a stance, allow yourself to explore both sides of the argument. This not only provides depth to your essay but showcases your ability to evaluate diverse perspectives.

Connect to Real-Life Situations : Anecdotes and real-world examples make your essay relatable and tangible. They serve as evidence of your claims and breathe life into abstract ideas.

Interlink Areas of Knowledge (AoK) : While the prompt may specify certain AoKs, don’t be afraid to draw connections to others if relevant. This showcases your holistic understanding and makes for an enriched argument.

Mind the WoKs (Ways of Knowing) : Whether it’s perception, emotion, reason, or language, remember that WoKs can offer unique angles and insights into your essay topic. Weave them in where appropriate.

Engage with Counterclaims : A well-rounded essay isn't just about asserting your perspective but recognizing and addressing counterarguments. This not only strengthens your position but exhibits critical thinking.

Stay Structured : While the ToK essay encourages deep thinking, remember that clarity is crucial. Use a clear introduction, body, and conclusion. Organize your thoughts systematically to guide the reader seamlessly through your arguments.

Personalize Your Insights : Remember, the ToK essay is a reflection of your intellectual journey. While you'll rely on experts and sources, don’t forget to interject with your personal insights, experiences, and reflections.

Revisit and Revise : First drafts are called 'first' for a reason. Once you've penned down your initial thoughts, take a break, return with fresh eyes, and refine your essay. This iterative process can be a game-changer in elevating the quality of your piece.

Now, with these strategies in hand, you're better equipped to face the ToK essay head-on. Remember, it's as much about the journey of exploration as it is about the final piece. Enjoy the process, relish the challenges, and if ever in doubt, our earlier guide is just a click away for some quick wisdom.

Final Tips for Tackling the ToK Essay Head-On

Alright, we've traversed the vast landscape of ToK essay prompts, delved deep into some of them, discussed strategies, and even looked into multimedia resources. But before you embark on your essay-writing journey, here are a few last-minute nuggets of wisdom to carry with you:

Stay Original : While it's great to gather insights and understand the general perspective on topics, always ensure your voice shines through. Adjudicators value originality and authenticity.

Seek Feedback : It's always a good idea to have someone else, be it a peer, teacher, or mentor, take a look at your essay. They might offer a perspective or insight that you hadn't considered.

Stay Within the Word Limit : It might seem challenging, but condensing your thoughts and being concise is key. Straying far from the word limit might make your essay seem unfocused.

Relax and Trust Yourself: Believe in your capabilities. Remember, this essay is as much about the journey of exploration as it is about the end product.

The Theory of Knowledge essay can indeed seem like a mammoth task. With multiple layers of interpretation and areas of knowledge to consider, the process can be daunting. But with the right strategies, resources, and mindset, it's a challenge you can certainly overcome.

And hey, if ever the waters seem too rough, remember you're not alone. Whether you need to go back to the basics with writing ToK essay or require hands-on assistance, there's always help at hand with IB writing service .

Last edit at Aug 15 2023

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With over a decade in the educational realm, Henrik has guided countless IB students towards academic excellence. Combining a deep understanding of the IB curriculum with practical strategies, Henrik is committed to making challenging subjects approachable and essays memorable.

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How To Write A ToK Essay - Updated 2023

Ace your ToK Essay with our expert tips & tricks! Get the latest and greatest techniques on "How To Write A ToK Essay" and impress the IB examiners.📝💡

Table of content

• Introduction

Purpose Of ToK

Assessment of tok, the game plan, execution of the gameplan, planning for tok essay, structure of tok essay, conclusions, bibliography.

Introduce your topic accurately and state your thesis statement for the essay carefully.  A thesis statement is like a teaser to your entire essay wherein you define your key terms and introduce your interpretation of the question. Make sure that you do not reword the prescribed title in your thesis. Instead, it needs to, as the word says, INTRODUCE your readers to what your essay is about. A strong introduction allows the reader to deduce what knowledge question(s) you are trying to answer.

So, in a nutshell

• Write interesting things about the given TOK essay title .
• Define key terms
• Narrow in on the particularly interesting aspect
• State your thesis statement . This will be your short answer to your given title if you don't know how to write a killer thesis statement check out this blog from SparkNotes .
• State your Roadmap. This will help the readers in understanding the direction of your essay.

How to write a TOK Essay? 

To answer that, you must familiarise yourself with what a TOK Essay is about.

Before you start reading this article,  Amanda  has some excellent TOK tips for you!

Theory of Knowledge is one of the most meta subjects that IB offers. Despite its complexity, TOK helps in providing a base for holistic learning and allows students to have a multidisciplinary experience. 

To understand TOK is to understand the essence of IB, a task that most people consider unattainable.

But not for you! 

Thank your lucky stars who made you land on Nail IB. How exactly will Nail IB help you? 

Well, nailing International Baccalaureate is something we will discuss later. 

Let's focus on cracking your TOK essay, shall we?

TOK demonstrates how students  can apply their knowledge  with  greater awareness  and  credibility .

Big words, huh? 

Now that we know that we cannot just slide through the Theory of Knowledge, let's understand how we can conquer this battle all guns blazing.

ToK essay’s primary objective is to answer the  why  behind our studies. 

It makes one aware of the real-life implications of their subjects. The students gain greater awareness of their personal and ideological assumptions and appreciate the diversity of different perspectives. It helps the students find their unique perception, a prerequisite for excelling in the IB TOK essays.

Before we dive into our gameplan, let’s overview the rules of the game.

There are two assessment tasks in the TOK: an essay and a presentation . While a presentation encourages students to explore a real-life situation through the lens of TOK, an essay is written on the basis of the various questions provided by the International Baccalaureate Organisation.

• The presentation is to assess a student’s ability to apply TOK thinking to a real-life situation whereas IB TOK essay is more conceptual.
• The essay is externally assessed by IB and must be on any one of the prescribed TOK essay titles issued by the IB for each examination session.
• Word limit of a TOK essay is 1600 words ( excludes extended notes, footnotes, bibliography).

Now that we have unleashed the game, let’s move ahead towards the gameplan of acing both, your presentation and your essay.

One of the fundamental tasks of TOK is to examine different areas of knowledge and find out their similarities and differences.

The TOK essay requires the students to investigate two Areas of Knowledge (AOK)  and two Ways of Knowing   (WOK) . AOKs and WOKs are investigated via questions such as:

• How do we know what we know? (WOK)
• What counts as evidence for X? (AOK)
• How do we judge which is the best model of Y? (WOK)
• What does theory Z mean in the real world? (AOK + WOK)

The aforementioned are  Knowledge Questions  which help combine the Areas of Knowledge and the Ways of Knowing that they are using. This eliminates the superficial way of learning and makes an individual sensitive to the nature of the information.   Our acquisition of Knowledge can be broadly divided into Shared Knowledge and Personal Knowledge.

Shared knowledge: What WE know It is the product of more than one individual. Although individuals contribute to it, shared knowledge does not solely depend upon the contributions of a particular individual—there are possibilities for others to check and amend individual contributions and add to the body of knowledge that already exists.

Personal knowledge: What I know It is essentially dependent on the experiences of a particular individual. Also known as procedural knowledge, it is gained through experience, practice and personal involvement and is intimately bound up with the particular local circumstances of the individual such as biography, interests, values, and so on.

The best hack to ace TOK essay is to develop a habit of making connections between the construction of knowledge, its acquisition and its relevance in the real world. 

After that one needs to develop an interest in understanding the difference between diversity and cultural perspectives and personal assumptions.

One also needs to critically reflect on their own beliefs and assumptions, leading to more thoughtful, responsible and purposeful lives.

Yes, this is what you signed up for. It may sound a little intimidating but once you get the hang of it you will be able to see the matrix and understand this beautiful world a little better.

Understand that to provide the best version of your writing, it will take you more than one or two drafts. First and foremost, you need to pick your essay topic diligently. Try to choose an essay topic that best interests you. The topic should also allow you to explore the Areas of Knowledge towards which you are naturally inclined. Here are a few sample questions:

a) 'Ways of knowing are a check on our instinctive judgments.' To what extend do you agree with this statement?

b) With reference to two areas of knowledge discuss the way in which shared knowledge can shape their personal knowledge.

c) How can we know if knowledge is produced more through 'Passive Observation' or 'Active-Experiment' within the Human and Natural-sciences under a Mathematical-Perspective?

d) "The whole point of knowledge is to produce both meaning and purpose in our personal lives". Assess the validity of this statement.

Great things take time. It took me more than a couple of weeks to finalize this TOK essay guide. It is completely okay if the first few drafts may not look pleasing or award-winning to you. You will require sharpening your perspective towards the topic each time you polish your draft. Your writing journey from a dull draft to a masterpiece will be a whole process that you will have to be patient with. Have faith in yourself and proceed stepwise.

You need to consider the opinions of others who have devoted hours of research and a lifetime of dedicated studying the topic that surrounds your writing. Unravelling the realms of your mind palace is so Sherlock but let’s not deny the fact that at times, Watson is the one whose expertise helps Sherlock through pretty difficult times. I mean even Batman needs a Robin. In support of my awesome sauce examples, the point I am trying to make is that  finding support for our claims and counterclaims through research is a good thing .

Use real-life examples to support your claims and counterclaims. These examples need to be documented researched examples like studies, experiments, articles, presentations by well-known people, etc. Examples that stem from your diploma subjects are highly encouraged, but those will need to be supported by research as well.   

It is suggested that you choose a title, stick to it, tackle it and not be afraid. Do not change your mind unless there is a good reason. Also, try choosing Areas of knowledge that you truly enjoy. You know slaying a known devil is much easier than an unknown one. Allot a TIMELINE to your essay. Start with creating an outline of your essay. This will help you to track your progress and accomplish your goals

You can use tools like  Trello  to organize your ideas and plan your TOK essay.

Areas of Knowledge (AOKs): TOK distinguishes between eight areas of knowledge. They are mathematics, the natural sciences, the human sciences, the arts, history, ethics, religious knowledge systems, and indigenous knowledge systems. It is suggested that students study and explore six of these eight.

Ways of knowing (WOKs): TOK identifies eight specific WOKs- language, sense perception, emotion, reason, imagination, faith, intuition, and memory. It is suggested that studying four of these eight in-depth would be appropriate. WOKs underlie the methodology of the areas of knowledge and provide a basis for personal knowledge.

Moving ahead, let us discuss the structure of your TOK essay.

Your essay will consist of 4 broad segregations

Before breaking down further on the pillars, keep the following in mind

• Please note what the TOK essay title is asking you. (Read it a couple of times. We highly recommend that you brainstorm ideas with your TOK coordinator)
• Make sure you understand the command term and the question it is asking.
• What kind of knowledge is being elicited?
• When choosing your areas of knowledge (AoK) and ways of knowing (WoK) make sure that you are able to draw contrasts and comparisons, that is, you are able to find evidence that supports as well as challenges your claims.
• Identify key terms in your TOK essay title. Make sure you define them. Your essay will gravitate around them. Key terms/words in your titles are your essay anchors. Your response should be built around them.
• Your writing skills come in handy while you work on your IB TOK essay. Like any other essay make sure you have proper thesis statements and topic sentences to guide the evaluator through your work.
• Respect the TOK essay title. Rephrasing the topic is not encouraged . Your main job is to address the title.

The body can be mainly divided into 3 segments.

Body (1st Segment)

• AoK Claim:  Here you investigate your first Area of Knowledge and draw parallels between your AoK and the question. This is done by stating your claim. Claims can be general in nature and need not reference a particular area of knowledge. They help you shape your essay and investigate the question further. 
• Evidence: Example of a real-life situation, describe thoroughly and accurately, which supports your stated claim. (AoK)
• Counter-Claim: State your counter-claim: like claims, those can be general and need not reference a particular area of knowledge. Counterclaim helps you show the other side the coin and gives your essay a holistic nature. 
• Evidence: A referenced real-life situation/example. Describe thoroughly and accurately, show how this supports your counterclaim (AoK ).
• Don’t forget to weave in your WoKs:  You need to take into account the source of your knowledge. Here you can also investigate if your nature of acquiring the knowledge has, in any way, affected it. It is good practice to question if your knowledge would be different had it been acquired through a different source/method
• Mini-conclusion: Here you analyze your examples in reference to your claims and counterclaims. You must connect to your thesis statement and the prescribed title. How does your proposed argument, in this particular part of the body, connect to the prescribed title and the knowledge questions you are trying to answer?

Body (2): Follow the above process for your second AOK.

• Use this part of your essay to compare and contrast your varying AoKs. You need to connect them to your thesis and your prescribed title clearly showing how your arguments respond to the PT.

Your conclusion section will make your essay come together. It is the glue that will make your essay stick together. Herein, you need to

• Reiterate your thesis (initial response).
• Use your mini conclusions to write a final conclusion.
• Tell the reader what the significance is for knowing what we know in this particular PT.
• Discuss implications as well.
• Offer another perspective, how will the perspective of a different person affect the claims/counterclaims you make in the essay?
• Don’t forget to make the end strong.

We recommend all the ib students use the  citation machine  (It's FREE) to organize or generate a bibliography for your TOK essay. Please go through this extensive guide provided by the IB before you start working on your citations.

If you are still struggling heaps with your TOK essay feel free to subscribe to our tok notes bundles or get access to more than 500+ IBDP notes and past papers here .

Nail IB is your virtual companion that helps you hustle through your diploma and provide you with the right resources at the right time. To know more about acing IB, click  here .

I hope this article will become the foundation for figuring out how to write a TOK Essay.

Remember to have faith in yourself.

I hope you NAIL your TOK essay!

Quoting the great Napolean Hill

"Whatever the mind of a man can conceive and believe, it can achieve."

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IB ToK Essay Titles and Topics: May 2021

Here are links to ideas and suggestions relating to the the six May 2021 IB ToK Essay topics:

• Topic 1. "Accepting knowledge claims always involves an element of trust." Discuss this claim with reference to two areas of knowledge.
• Topic 2. Within areas of knowledge, how can we differentiate between change and progress? Answer with reference to two areas of knowledge.
• Topic 3. "Labels are a necessity in the organization of knowledge, but they also constrain our understanding." Discuss this statement with reference to two areas of knowledge.
• Topic 4. "Statistics conceal as much as they reveal." Discuss this claim with reference to two areas of knowledge.
• Topic 5. "Areas of knowledge are most useful in combination with each other." Discuss this claim with reference to two areas of knowledge.
• Topic 6. " Avoiding bias seems a commendable goal, but this fails to recognize the positive role that bias can play in the pursuit of knowledge." Discuss this statement with reference to two areas of knowledge.

Title 1: "Accepting knowledge claims always involves an element of trust." Discuss this claim with reference to two areas of knowledge.

Thoughts to consider with essay 1 include:

• is trust simply the same as the WOK faith?
• what is the difference between trusting oneself and trusting others?
• are self-evident truths taken on trust?

Title 2: Within areas of knowledge, how can we differentiate between change and progress? Answer with reference to two areas of knowledge.

Thoughts to consider with essay 2 include:

• the role of truth in distinguishing change and progress
• the functions or uses of knowledge
• the role of rational justification in defending knowledge claims

Title 3: "Labels are a necessity in the organization of knowledge, but they also constrain our understanding." Discuss this statement with reference to two areas of knowledge.

Thoughts to consider with essay 3 include:

• are mental concepts labels?
• the role of the imagination in pushing the boundaries of unconstrained knowledge
• the difference between analysing something and labelling it

Title 4: "Statistics conceal as much as they reveal." Discuss this claim with reference to two areas of knowledge.

Thoughts to consider with essay 4 include:

• the difference between descriptive and inferential statistics
• the difference between subjective and objective probability
• what is the difference between appearance and reality?

Title 5: "Areas of knowledge are most useful in combination with each other." Discuss this claim with reference to two areas of knowledge.

Thoughts to consider with essay 5 include:

• the way different questions are asked in different AOKs
• the different methods that each AOK uses to answer its distinctive questions
• how can AOKs combine without merging and losing their identity?

Title 6: " Avoiding bias seems a commendable goal, but this fails to recognize the positive role that bias can play in the pursuit of knowledge." Discuss this statement with reference to two areas of knowledge.

Thoughts to consider with essay 6 include:

• can we ever see the world, as it is, without using concepts?
• do we need bias to form hypotheses in the imagination?
• what is the difference between an objective and a subjective judgement?
• 1. "Accepting knowledge claims always involves an element of trust." Discuss this claim with reference to two areas of knowledge.
• 2. Within areas of knowledge, how can we differentiate between change and progress? Answer with reference to two areas of knowledge.
• 3. "Labels are a necessity in the organization of knowledge, but they also constrain our understanding." Discuss this statement with reference to two areas of knowledge.
• 4. "Statistics conceal as much as they reveal." Discuss this claim with reference to two areas of knowledge.
• 5. "Areas of knowledge are most useful in combination with each other." Discuss this claim with reference to two areas of knowledge.
• 6. " Avoiding bias seems a commendable goal, but this fails to recognize the positive role that bias can play in the pursuit of knowledge." Discuss this statement with reference to two areas of knowledge.
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TOK exhibition IA prompts

TOK Home > Free TOK notes > TOK exhibition > TOK exhibition IA prompts

The TOK exhibition prompts

Once you’ve understood the  basics , and have grasped what the  assessment rubric  is looking for, you can think about which IA prompt to choose. This comes from the list of 35 prompts in the TOK subject guide.   Your IA prompt links your three objects to the TOK course, and enables you to demonstrate how TOK manifests itself in the real world. The context you’ll use for this will be either the  core theme  or one of the  optional themes .

Selecting an exhibition prompt

The ‘bq filter’.

35 prompts mean that there is a lot of choice with your exhibition, and it’s easy to get lost amongst all the possibilities. By applying a filter to the prompts you’ll understand them better, and be able to make more sense about what they are asking. Our way of structuring the course should help you. We divide the course up into 6 ‘Big questions’ (BQs), each one of which exploring a different aspect or concept related to TOK. You can see the BQs on  here .

Think about the aspect or concept behind each BQ, and then match this up to what’s being asked by the IA prompts. For example BQ2 looks at the relationship between knowledge and how we construct our values. This links to several IA prompts that focus on ethics, such as 16 and 27. BQ4 explores bias and perspectives. A lot of the IA prompts relate to this; for example, 12 and 28.

After you have matched up the BQs to the IA prompts, you begin choosing one that will work for you. Be motivated by what interests you, what matches up to concepts you’ve found interesting during the TOK course, and what resonates with your own experiences, both inside and outside school.

Your exhibition should be set within the context of the core theme, or the optional themes. So your third step is to head over to those sections of the site, and have a look at the Big Question that relates to your IA prompt. Check out the quotes, the notes, and the real-life situations that we’ve put together. This will give you more of an idea about what your exhibition will focus on, and the objects that you’ll select.

Putting this in context…

Let’s say that you’ve decided to construct an exhibition that deals with the way we communicate ideas. This aligns with Big Question 3. You like the look of IA prompt number 24, which looks at the effect of the context which knowledge is presented. You’d like to base your exhibition on technology.

You’d head over to  this page  of the site, and find quotes and real-life situations that relate to this BQ/IA prompt, within the context of technology. Note that if your school has  membership  to the site, you’ll be able to access the ‘exploration points’, which identify key terms and words, and suggestions on how to unpack the media sources.

TOK exhibition pages

The TOK exhibition rubric

Learn about how the exhibition is marked, and the skills you are expected to demonstrate in order to succeed. Find out more here .

Find out about the IA prompts used to write your exhibition commentary, and tips on choosing the right one. Read more here .

The TOK exhibition objects

Find out what ‘exhibition objects’ are, how to choose effective ones, and linking them to a theme and prompt. Read more here .

The TOK exhibition commentary

Learn about the 950-word exhibition commentary, ways to link it to your IA prompt, and how to set it within a theme. Find out more here .

Putting on the exhibition

Get tips on how to set up a TOK exhibition, talking in public, and showing off your TOK knowledge to a public audience. Find out more here .

More support for the TOK exhibition

Make sure that your TOK teacher has given you access to all the documents and online material that support the exhibition. These include the TOK Subject Guide (for the 2022 syllabus) – where you’ll find the IA prompts, and the exhibition rubric – and the exemplar TOK exhibitions (found in ‘MyIB’, which is accessible to teachers).   Follow the links above to take you to the three different elements of the TOK exhibition; we’ve also created a page giving some tips on how to put on your exhibition if your school is running a public ‘exhibition day’ which you can visit  here . It suggests ways of presenting ideas to an audience.   If your school is a  member  of theoryofknowledge.net, we have designed a series of lessons on the exhibition, with a three practice exhibition tasks. These will familiarize you with the IA prompts, how to select effective objects, and the assessment rubric. If you are signed into the site, you can access these lessons  here .

Access our exhibition prompt decoder

Our exhibition prompt decoder enables students to link each of the 35 IA prompts to the 12 key TOK concepts, to the BQs, and to the core and optional themes. It will allow students to explore their choice of prompt for the exhibition via questions, quotes, media sources, and key thinkers.

You can also find out our thoughts on the TOK exhibition (and the TOK essay) in several webinars that we have delivered. The main one is the TOK Assessment 2022 webinar, but we also consider this form of assessment in our free webinars on the 2022 course. You can see these webinars on  this page  of the site.

FAQs about the exhibition IA prompts

How many tok exhibition prompts are there.

There are 35 TOK exhibition prompts. You will choose one of them, and it should relate to each of your three objects.

Where can I view the TOK exhibition prompts?

The prompts are found on pages 40-41 of the TOK subject guide (for the 2022 syllabus). Your TOK teacher will give you a copy of this, or give you the list of prompts on a separate document.

How do I link the IA prompts to the TOK course?

The IB strongly recommends (ie, this is what you should do) that your IA prompt should be explored within the context of the  core theme  or one of the  optional themes . So when you choose one of the prompts, think about how it relates to knowledge & the knower, language, technology, etc.

Can I change the way the IA prompt is worded?

Absolutely not – just like the , you should explore it exactly as it is expressed.

Get real with TOK by subscribing to the newsletter

Step into the real and unpackaged world by subscribing to our unique monthly TOK newsletter. You’ll receive links to great media sources from all over the world that place the TOK themes and areas of knowledge into an authentic context.

You’ll meet great thinkers and ideas, hone your understanding of key TOK concepts, and build up a library of examples for the essay and exhibition. Subscribe HERE !

TOK DISCUSSIONS

“Now I know how to write my essay, am not afraid anymore.”

Theory of Knowledge Assessments Ultimate Guide is the only guide you need to get an A in IB TOK Essay and Exhibition. The book has five chapters, each of which explains in detail how to master the TOK course and pass TOK assessments with flying colors. You can follow its step-by-step method to choose your IA prompt, and essay title, create your exhibition, and write your TOK essay. You will also benefit from suggested objects , themes , AOKs , RLEs , samples texts from actual assessed works , and sample analytical texts .

You will learn,

how to choose the “right” essay title, and IA prompt.

how to form guiding knowledge questions, and develop your arguments.

how to write the essay's introduction and conclusion paragraphs, and exhibition commentaries.

You will have access to,​

full explanations of all 35 IA prompts.

sample texts from students actual assessed works.

suggested objects, themes, AOKs, and RLEs.

15 sample analytical texts written for IA prompts and official prescribed titles.

- IB1 Student

“It’s a goldmine where each DP student and DP teacher “must” go and mine.”

- TOK Teacher

“I can make everyone surprised by my ability to organize and explain the ideas.”

- IB2 Student

“It took half of my daughter's stress away.”

- IB Parent

“The best part ... is about how to write good/bad claims and counterclaims and the analogy of the courtroom.”

Read on Google and Amazon .

Title Knowledge Question (May 2022 session prescribed titles): To what extent do you agree with the claim that “there’s a world of difference between truth and facts” (Maya Angelou)? Related Optional Theme: Knowledge and Politics Related Area of Knowledge: History Related Knowledge Framework Element: Perspectives

Putin Calls Ukrainian Statehood a Fiction. History Suggests Otherwise.

In the summer of 2021, Russian president, Vladimir Putin, published an essay, “On the Historical Unity of Russians and Ukrainians.” In his essay, Putin explains the “truth” about the unity of all Russians, Belarusians, and Ukrainians, by bringing countless historical “facts” in his pursuit to convince the world that Ukrainian statehood was nothing but a fiction created by the Bolshevik, communist Russia under the leadership of Vladimir Lenin. The title question I chose for this text asks us to explore and express the extent of our agreement with a quote from American poet Maya Angelou that says, “there’s a world of difference between truth and facts.” I chose a tweet by The New York Times on Feb 22, 2022, only two days before Russia invaded Ukraine, that studies the Russian president’s “facts” and “truth” behind his invasion as my RLE/object. continue reading in the book

Title Knowledge Question (IA prompts): Can new knowledge change established values or beliefs? Related Optional Theme: Knowledge and Religion Related Area of Knowledge: The Human Sciences Related Knowledge Framework Element: Perspectives

Germany's largest mosque to broadcast call to prayer on Fridays

On October 11, 2021, Reuters tweeted on its Twitter account, linking to one of its news reports on the largest mosque in Germany. It reports that the largest mosque in Cologne, also the largest in Germany, “will be permitted to broadcast the call to prayer over loudspeakers” only at a specific time of the week. The title question for this text, IA prompt #11, asks us to explore whether new knowledge can change established values or beliefs. I assume it is best to find out what “knowledge” is in this news story and what “values” and “beliefs” are already established by a group of knowers.  continue reading in the book

Title Knowledge Question (May 2022 session prescribed titles): How can we distinguish between good and bad interpretations? Related Optional Theme: Knowledge and Language Related Area of Knowledge: The Arts Related Knowledge Framework Element: Methods and Tools

Renegades: Born in the USA

On October 26, 2021, a book titled “Renegades: Born in the USA” was published, which was based on a podcast of the same name, as a series of conversations between two longtime friends, Barack Obama and Bruce Springsteen. The title and the theme are inspired by the singer’s bestselling album also song, Born in the USA, which is also considered one of the most misunderstood songs in America. The title question for this text asks us to explore the differences between “good” and “bad” interpretations and how to distinguish these from each other. Rereading the story behind this song and studying what happened after its release with all the misinterpretations may take us closer to the point where “good” and “bad” interpretations separate.

continue reading in the book

Title Knowledge Question (IA prompts): Are some types of knowledge more useful than others? Related Optional Theme: Knowledge and Indigenous Societies Related Area of Knowledge: The Natural Sciences Related Knowledge Framework Element: Methods and Tools

Australia fires: Aboriginal planners say the bush ‘needs to burn’

Bushfires in Australia are considered by many a serious rampant natural phenomenon leading to the death of human beings and animals and the destruction of lands and cities. Aboriginal Australians think differently. At the beginning of 2020, Gary Nunn, journalist and author, wrote a news article for BBC News (World), bringing another contrasting perspective to the heated discussion surrounding the bushfires and how to control them. The title question asks whether “some types of knowledge are more useful than others,” I intend to explore this question within the theme of Knowledge and Indigenous Societies and AOK of The Natural Sciences through the lens of the TOK element of Methods and Tools. I have to clarify something in the beginning, that “methods and tools” of producing knowledge, in this text, are not to be mistaken for the differences between the methods and techniques used by modern organizations and those used by aboriginal Australians.  continue reading in the book

Title Knowledge Question (November 2021 session prescribed titles): “There is nothing more deceptive than an obvious fact” (Arthur Conan Doyle). Related Optional Theme: Knowledge and The Knower Related Area of Knowledge: The Natural Sciences Related Knowledge Framework Element: Ethics

The Doctor Who Fooled the World

In Epistemology, a branch of philosophy, sometimes referred to as the Theory of Knowledge, “self-evident truth” or “obvious fact” is a proposition known to be true by understanding its meaning without proof or, simply, by ordinary human reason. The discussion is of a complex nature, and examples need comprehensive explanations and explorations to be fully understood. What I think Sir Arthur Conan Doyle, the creator of Sherlock Holmes, intended in this quote (from one of his mysterious stories), title of this text, “there is nothing more deceptive Nov ’21 Prescribed Title #3 □ 143 than an obvious fact,” is not the philosophical meaning of “obvious fact” and rather the common daily understandable of the term. “Obvious fact” could be something that “everyone knows,” something that is so “obvious” that it does not leave room for further investigation or exploration. Therefore, the quote implies that, at times, we encounter situations or claims that are readily acceptable based on what we already believe. “Everyone knows that smoking is bad for health,” or “if you want to have a good life, you need to go to college and get a good degree,” and many more examples of this kind.  continue reading in the book

And 10 More for You to Study!

IB TOK Essay examples

Type a search phrase to find the most relevant TOK Essay examples for you

Not sure what to search for? You can always look through our example Theory of Knowledge coursework below for inspiration.

All TOK Essay Examples

Filter exemplars, to what extent is the knowledge we produce determined by the methodologies we use discuss with reference to history and one area of knowledge., does it matter if our acquisition of knowledge happens in "bubbles" where some information and voices are excluded discuss with reference to two areas of knowledge., want to get full marks for your tok essay allow us to review it for you 🎯, is replicability necessary in the production of knowledge discuss with reference to two areas of knowledge., for artists and natural scientists, which is more important: what can be explained or what cannot be explained discuss with reference to the arts and the natural sciences., are visual representations always helpful in the communication of knowledge discuss with reference to the human sciences and mathematics., fast track your coursework with mark schemes moderated by ib examiners. upgrade now 🚀, tok essay: 5. “how can we distinguish between good and bad interpretations discuss with reference to the arts and one other area of knowledge”, 如果我们是在排除某些信息和声音的“信息同温层”里获取知识，这有关系吗请参考两个知识领域展开你的应答。, does it matter if our knowledge acquisition happens in "bubbles" where some information and voices are excluded discuss with reference to two areas of knowledge., is replicability necessary in the production of knowledge discuss with reference to two areas of knowledge, do you agree that it is “astonishing that so little knowledge can give us so much power” (bertrand russell) discuss with reference to the natural sciences and one other area of knowledge., does it matter if our acquisition of knowledge happens in “bubbles” where some information and voices are excluded discuss with reference to two areas of knowledge., to what extent is the knowledge weproduce determined by the methodologieswe use, for artists and natural scientists, which is more important: what can be explained or what cannot be explained discuss with reference to the arts and natural science., êtes-vous d'accord qu'il est "étonnant que si peu de connaissance puissent nous donner autant de pouvoir" (bertrand russell) - discutez cette question en faisant référence aux sciences naturelles et à un autre domaine de la connaissance, est-il important que notre acquisition des connaissances se fasse dans des « bulles » où certaines informations et certaines voix sont exclues discutez cette question en faisant référence à deux domaines de la connaissance., to what extent is the knowledge we produce determined by the methodologies we use discuss with reference to history and one other area of knowledge., is replicability necessary in the production of knowledge discuss with reference to two area of knowledge, are visual representations always helpful in communicating knowledge discuss with reference to the human sciences and mathematics., are visual representations always useful in communication of knowledge discuss with reference to the human sciences and mathematics., for artists and natural scientists which is more important: what can be explained or what cannot be explained, do you agree that it is "astonishing that so little knowledge can give us so much power" (bertrand russell) discuss with reference to the natural sciences and one other area of knowledge., is replicability necessary in the production of knowledge, is replication necessary in the production of knowledge discuss with reference to two aoks..

Unpacking the 2024 November TOK Titles: A Comprehensive IB Solved Guide

The November 2024 IB Theory of Knowledge (TOK) Essay Titles are out!

Let's be honest – tackling the TOK essay can be a daunting task. With so many ideas, concepts and topics at our disposal and a myriad of ideas swirling around, it's easy to feel overwhelmed at the outset.

That's where we come in.

In this article, we'll delve into each title and offer some strategic advice on how to approach them.

General Tips to Unpacking a Title

When we first encounter a prompt, we want to think in terms of perspectives and counter-perspectives (formerly known as claims and counterclaims). This framework allows for a structured essay, exploring the title through the lens of two chosen Areas of Knowledge (AOKs) and weaving in different arguments. While the ultimate conclusion you draw may often reside somewhere between these extremes or on a conditional basis (e.g. perspective 1 is correct in certain circumstances, while perspective 2 is a better approach in other), starting with opposing arguments can facilitate the development of a more nuanced exploration and argument.

So let's get to it – here is everything you need to know about the November 2024 TOK Essay titles:

Title 1:  Does our responsibility to acquire knowledge vary according to the area of knowledge? Discuss with reference to history and one other area of knowledge.

Recommended AOKs: History (Mandatory) and Natural Sciences/The Arts/Human Sciences

This title prompts an assessment of whether we have different levels of responsibility to acquire knowledge across different AOKs. While you are open to argue against the title directly, suggesting that the responsibility is the same across AOKs, this would be unwise. It would be better to reflect on each AOK and perhaps present one perspective in support of the responsibility and one perspective against it, drawing a conclusion on which argument is stronger in each AOK.

Also consider the difference between the acquisition and production of knowledge – perhaps we have a broader responsibility to produce new knowledge in some areas of knowledge but not necessarily to acquire it as individual knowers.

Some perspectives you may consider:

Perspective: We have a responsibility to acquire knowledge to ensure that we construct an accurate record of the past. It is our responsibility to know our History and learn from the past.

Counter-Perspective: Historical knowledge is limited by subjectivity and collective memory, hence it is not essential to acquire knowledge of our past to build a successful future.

Perspective: We have a responsibility to acquire artistic knowledge to understand cultures and societies.

Counter-Perspective: The acquisition of knowledge in the Arts is for aesthetic purposes and enjoyment, not the fulfilment of a responsibility.

Natural Sciences/Human Sciences

Perspective: We have a responsibility to acquire new scientific knowledge for the continual development of mankind.

Counter-Perspective: Understanding how the world/humans work is not necessary knowledge for knowers to acquire.

Title 2:  In the production of knowledge, is ingenuity always needed but never enough? Discuss with reference to mathematics and one other area of knowledge.

Recommended AOKs: Mathematics (Mandatory) and Natural Sciences/The Arts/Human Sciences

This is a super interesting title – ensure you define 'ingenuity' from the outset. The essay almost structures itself – your first paragraph in each AOK can consider how/whether ingenuity is 'always needed', exploring how this plays out in each AOK, while the second paragraph can explore whether or not it is 'never enough'.

Some ideas you may consider:

Paradigm Shifts – To revolutionise an AOK, often ingenuity is needed to enact a paradigm shift (a new way of thinking which changes the entire knowledge structure of an AOK) and to ensure progress.

Creativity – Creative thinking is important not only for AOKs such as the Arts, but even in Mathematics and the Sciences. Discovering innovative ways of devising experiments or utilising clever analogies to explain incredibly complex concepts is integral to these AOKs.

Structure – Ingenuity is only valuable within a framework for knowledge production, whether this be an artistic process or the scientific method.

Title 3:  How might it benefit an area of knowledge to sever ties with its past? Discuss with reference to two areas of knowledge.

Recommended AOKs: History, Natural Sciences, The Arts and Human Sciences

The 'How' of this title restricts the scope to discussing different 'benefits' rather than a standard 'perspective-counter' analysis. It will also be important to define exactly what 'severing ties' involves – does this mean completely ignoring all past knowledge or simply becoming less attached to existing ways of thinking?

Some ideas for this title:

Fresh Ideas and Paradigm Shifts – By severing ties, you open up the possibility of acquiring knowledge which can overhaul an entire AOK, drastically accelerating progress.

Bias – By severing past ties, knowers can free themselves of the biases of their predecessors.

Innovation – Since existing frameworks of thinking often lead to similar conclusions, you can expand the possibilities of new knowledge by severing past ties.

However, you may interestingly conclude that these benefits are only reaped when ties to the past are severed to an extent, as it may be detrimental to an AOK to entirely negate past knowledge.

Title 4:  To what extent do you agree that there is no significant difference between hypothesis and speculation? Discuss with reference to the human sciences and one other area of knowledge.

Recommended AOKs: Human Sciences and History/Natural Sciences

This prompt is very focused on your definitions. I would suggest defining these terms distinctly and precisely from the outset. The primary question which this title is asking is whether hypotheses are mere "speculation" or "guesses", or if there is a significant difference.

Also, if selecting the Human and Natural Sciences, please ensure that your perspectives aren't repetitious and highlight the differences between these AOKs.

Development – Speculation and hypothesis differ in the fact that the development of a hypothesis generally requires significant prior research and an understanding of existing knowledge

Experimentation – Hypotheses are developed purposefully and then empirical experimentation are conducted to provide evidence either in support or against them

Emotion – Speculation tends to come from 'feelings' or 'impressions', whereas the development of a hypothesis is far more methodical

Title 5:  In the production of knowledge, are we too quick to dismiss anomalies? Discuss with reference to two areas of knowledge.

Recommended AOKs: Human Sciences/History/Natural Sciences

This title allows you to reflect on whether or not we dismiss 'anomalies' (a key term to be defined) too quickly when producing knowledge.

Paradigm Shift – Anomalies are often the prompt for a paradigm shift in the sciences, causing us to challenge existing beliefs and ideas

Exceptions – Often rather than investigating anomalies further and considering an overhaul of existing knowledge, anomalies are dismissed as 'exceptions' to the rule, rather than a justification to question the rule itself

Generalisation – There is often a focus on generating 'general' rules and theories which can lead anomalies to be dismissed (think of the Human Sciences – how often do we produce a rule about human behaviour but ignore those who behave contrary to the rule)

Title 6:  In the pursuit of knowledge, what is gained by the artist adopting the lens of the scientist and the scientist adopting the lens of the artist? Discuss with reference to the arts and the natural sciences.

Recommended AOKs: The Arts and the Natural Sciences

This title requires you to define the 'lens' of each of these AOKs from the outset. It will be better to define them quite opposingly – the scientist is more methodical, experimental and structured, whilst the artist is more free-flowing and creative. You will then be able to take these attributes and argue which elements would be better across the two disciplines.

Creativity – Scientists can benefit from the creativity of artists when developing innovative ways of experimenting, presenting results and constructing abstract theories

Structure – Artists can often benefit from a methodical approach to constructing art, particularly when aiming to convey a specific message or purpose through their art

Flexibility – Artists are often quite flexible when constructing an artwork, always willing to change and adapt to their free-flowing thoughts, an attribute which is highly beneficial for scientists who at times may become rigid in their thinking and fixed to pre-existing scientific beliefs.

And that's it - our comprehensive guide to the 2024 November TOK Titles! If you're still racking your brain as to how to begin the writing process for your TOK essay, why not check out our post on The Complete IB TOK Essay Guide . Or check out one of our Grade A Exemplar TOK Essays ! Or better yet, if you are looking for some more personal assistance with your IB TOK Essay, click below to reach out to us and we can work with you through the entire writing process, from title selection to the best structure for success!

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TOK Chronicles: Decoding the TOK Essay Prompts for May 2024

As the May 2024 International Baccalaureate (IB) assessment approaches, students preparing for the Theory of Knowledge (TOK) Essay are faced with intriguing and thought-provoking prompts. These essay topics delve into the essence of knowledge, challenging students to explore various facets of how we acquire, interpret, and utilize information. In this guide, we will dissect each of the six essay prompts, providing insights and considerations for students embarking on their TOK Essay journey.

1. Is subjectivity overly celebrated in the arts but unfairly condemned in history? Discuss with reference to the arts and history.

This prompt challenges students to delve into the intricate relationship between subjectivity and objectivity in the realms of the arts and history. It prompts a sophisticated exploration of the interplay between the two, urging students to consider the celebration of subjectivity in the arts and the potential unfair condemnation of subjectivity in historical narratives. The essay should focus on the methodologies in each discipline, discussing how subjectivity manifests and whether it is a constructive or destructive force in knowledge production.

2. How can we reconcile the opposing demands for specialization and generalization in the production of knowledge? Discuss with reference to mathematics and one other area of knowledge.

This prompt delves into the tension between specialization and generalization in knowledge production. Students are encouraged to define these terms in a TOK context and discuss how each demand affects the production of knowledge. By referencing mathematics and another AOK, such as literature or natural sciences, students can explore the unique challenges and benefits associated with specialization and generalization and ponder how these demands can be reconciled.

3. Nothing is more exciting than fresh ideas, so why are areas of knowledge often so slow to adopt them? Discuss with reference to the human sciences and one other area of knowledge.

Addressing the sluggish adoption of fresh ideas in various AOKs, this prompt prompts students to examine the dynamics of knowledge adoption. Focusing on the human sciences and another AOK, students can explore factors influencing the pace of adoption, such as societal acceptance, methodological considerations, and the nature of each discipline. The essay should consider whether the pace of adoption is justified or if there are inherent challenges hindering the assimilation of new ideas.

4. Do we underestimate the challenges of taking knowledge out of its original context and transferring it to a different context? Discuss with reference to two areas of knowledge.

This prompt encourages an exploration of the challenges associated with transferring knowledge across different contexts. By referencing two AOKs, students can discuss the implications of removing knowledge from its original setting and examine how context influences interpretation. The essay should analyze whether the difficulties of transferring knowledge are underestimated and consider the impact of this process on the reliability and validity of the knowledge.

5. Do we need custodians of knowledge? Discuss with reference to two areas of knowledge.

Exploring the concept of custodianship, this prompt encourages students to evaluate the necessity of individuals or entities safeguarding knowledge. By referencing two contrasting AOKs, students can examine the role of custodians in preserving, disseminating, and potentially limiting knowledge. The essay should delve into the impact of custodianship on the nature and accessibility of knowledge within each AOK.

6. Are we too quick to assume that the most recent evidence is inevitably the strongest? Discuss with reference to the natural sciences and one other area of knowledge.

Challenging the assumption that the most recent evidence is always the strongest, this prompt prompts students to explore the dynamics of evidence evaluation. Referencing the natural sciences and another AOK, students can analyze how the validity and strength of evidence vary across disciplines. The essay should consider the factors influencing the perceived strength of evidence, such as methodologies, societal expectations, and the nature of the knowledge in question.

As students grapple with these compelling TOK Essay prompts, a journey of critical thinking and exploration unfolds. Each topic invites a unique perspective and challenges students to apply TOK concepts in real-world contexts. By delving into the intricacies of replicability, the explicable and the inexplicable, information bubbles, the relationship between knowledge and power, visual representations, and the impact of methodologies, students embark on a voyage of intellectual discovery integral to the TOK experience.

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Connecting the Dots: TOK Core Theme

Tok chronicles: understand the concept of effective research, tok chronicles: exploring truth, perception, and belief, unveiling the essence of ib diploma programme's tok, how and why ibdp tok is a vital subject, guidelines for crafting claims and counterclaims in your tok essay, a breakdown of the five optional themes in tok, a comprehensive guide on your tok journal.

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TOK TIPS: Resources for DP Theory of Knowledge

Tok exhibition, tok ia exhibition – pollution solution in kenya.

The TOK exhibition is focused on one of the 35 prompts and three “objects” chosen by the students. Review the prompt and object guidelines requirement and see how you could use the following for one section of an exhibition. BBC Read more…

TOK IA exhibition – oil sands

The TOK exhibition is focused on one of the 35 prompts and three “objects” chosen by the students. Review the prompt and object guidelines requirement and see how you could use the following for one section of an exhibition. “A Read more…

TOK IA exhibition – Greta Thunberg article

Article: https://www.bbc.com/news/world-europe-50740324 The TOK exhibition is focused on one of the 35 prompts and three “objects” chosen by the students. Review the prompt and object guidelines requirement and see how you could use the following for one section of an Read more…

TOK IA exhibition – BBC article on an atheist in India

The TOK exhibition is focused on one of the 35 prompts and three “objects” chosen by the students. Review the prompt and object guidelines requirement and see how you could use the following for one section of an exhibition. “An Read more…

TOK IA exhibition – aboriginal handcuffed in bank

The TOK exhibition is focused on one of the 35 prompts and three “objects” chosen by the students. Review the prompt and object guidelines requirement and see how you could use the following for one section of an exhibition. “Maxwell Read more…

TOK IA exhibition – protest graffiti

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May 2023 Prescribed Title #1

May 2023 tok essay prescribed title #1 specific example – japanese myth on the birth of japan..

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USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 1 of 70 IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT TIKTOK INC., and BYTEDANCE LTD., V. ) Petitioners, No. 24-1113 MERRICK B. GARLAND, in his official capacity as Attorney General of the United States, (Page 1 of Total) Respondent. PETITION FOR REVIEW OF CONSTITUTIONALITY OF THE PROTECTING AMERICANS FROM FOREIGN ADVERSARY CONTROLLED APPLICATIONS ACT

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 2 of 70 2. That law 1. Congress has taken the unprecedented step of expressly singling out and banning TikTok: a vibrant online forum for protected speech and expression used by 170 million Americans to create, share, and view videos over the Internet. For the first time in history, Congress has enacted a law that subjects a single, named speech platform to a permanent, nationwide ban, and bars every American from participating in a unique online community with more than 1 billion people worldwide. the Protecting Americans From Foreign Adversary Controlled Applications Act (the "Act") is unconstitutional. Banning Tik Tok is so obviously unconstitutional, in fact, that even the Act's sponsors recognized that reality, and therefore have tried mightily to depict the law not as a ban at all, but merely a regulation of TikTok's ownership. According to its sponsors, the Act responds to TikTok's ultimate ownership by ByteDance Ltd., a company with Chinese subsidiaries whose employees support various Byte Dance businesses, including TikTok. They claim that the Act is not a ban because it offers Byte Dance a choice: divest TikTok's U.S. business or be shut down.1 ― - 1 References to "TikTok Inc." are to the specific U.S. corporate entity that is a Petitioner in this lawsuit and publishes the TikTok platform in the 1 (Page 2 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 3 of 70 3. But in reality, there is no choice. The "qualified divestiture" demanded by the Act to allow TikTok to continue operating in the United States is simply not possible: not commercially, not technologically, not legally. And certainly not on the 270-day timeline required by the Act. Petitioners have repeatedly explained this to the U.S. government, and sponsors of the Act were aware that divestment is not possible. There is no question: the Act will force a shutdown of TikTok by January 19, 2025, silencing the 170 million Americans who use the platform to communicate in ways that cannot be replicated elsewhere. 4. Of course, even if a "qualified divestiture" were feasible, the Act would still be an extraordinary and unconstitutional assertion of power. If upheld, it would allow the government to decide that a company may no longer own and publish the innovative and unique speech United States. References to "TikTok" are to the online platform, which includes both the Tik Tok mobile application and web browser experience. References to “ByteDance Ltd." are to the specific Cayman Islands- incorporated holding company that is identified in the Act and is a Petitioner in this lawsuit. References to "ByteDance" are to the ByteDance group, inclusive of ByteDance Ltd. and relevant operating subsidiaries. TikTok Inc. and ByteDance. Ltd. are together referred to as "Petitioners." (Page 3 of Total) 21

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 4 of 70 platform it created. If Congress can do this, it can circumvent the First. Amendment by invoking national security and ordering the publisher of any individual newspaper or website to sell to avoid being shut down. And for Tik Tok, any such divestiture would disconnect Americans from the rest of the global community on a platform devoted to shared content an outcome fundamentally at odds with the Constitution's commitment to both free speech and individual liberty. 5. There are good reasons why Congress has never before enacted a law like this. Consistent with the First Amendment's guarantee of freedom of expression, the United States has long championed a free and open Internet - and the Supreme Court has repeatedly recognized that speech "conveyed over the Internet” fully qualifies for “the First Amendment's protections." 303 Creative LLC v. Elenis, 600 U.S. 570, 587 (2023). And consistent with the fundamental principles of fairness and equal treatment rooted in the Bill of Attainder Clause and the Fifth Amendment, Congress has never before crafted a two-tiered speech regime with one set of rules for one named platform, and another set of rules for everyone else. (Page 4 of Total) 3

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 5 of 70 6. In dramatic contrast with past enactments that sought to regulate constitutionally protected activity, Congress enacted these extreme measures without a single legislative finding. The Act does not articulate any threat posed by Tik Tok nor explain why TikTok should be excluded from evaluation under the standards Congress concurrently imposed on every other platform. Even the statements by individual Members of Congress and a congressional committee report merely indicate concern about the hypothetical possibility that TikTok could be misused in the future, without citing specific evidence - even though the platform has operated prominently in the United States since it was first launched in 2017. Those speculative concerns fall far short of what is required when First Amendment rights are at stake. 7. Nor is there any indication that Congress considered any number of less restrictive alternatives, such as those that Petitioners developed with the Executive Branch after government agencies began evaluating the security of U.S. user data and the risk of foreign government influence over the platform's content as far back as 2019. While such concerns were never substantiated, Petitioners nevertheless (Page 5 of Total) 4

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 6 of 70 worked with the government for four years on a voluntary basis to develop a framework to address the government's concerns. 8. As part of this engagement, Petitioners have voluntarily invested more than $2 billion to build a system of technological and governance protections sometimes referred to as "Project Texas" - to help safeguard U.S. user data and the integrity of the U.S. TikTok platform against foreign government influence. Petitioners have also made extraordinary, additional commitments in a 90-page draft National Security Agreement developed through negotiations with the Committee on Foreign Investment in the United States ("CFIUS”), including agreeing to a “shut-down option” that would give the government the authority to suspend TikTok in the United States if Petitioners violate certain obligations under the agreement. 9. Congress tossed this tailored agreement aside, in favor of the politically expedient and punitive approach of targeting for disfavor one publisher and speaker (TikTok Inc.), one speech forum (TikTok), and that forum's ultimate owner (ByteDance Ltd.). Through the Act's two-tiered. structure, Congress consciously eschewed responsible industry-wide. regulation and betrayed its punitive and discriminatory purpose. 5 (Page 6 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 7 of 70 Congress provided every other company however serious a threat to - national security it might pose - paths to avoiding a ban, excluding only Tik Tok Inc. and ByteDance Ltd. Indeed, for any other company's application to be banned, Congress mandated notice and a "public report" describing "the specific national security" concern, accompanied by supporting classified evidence. For Petitioners only, however, there is no statement of reasons and no supporting evidence, with any discussion of the justifications for a ban occurring only behind closed doors. 10. Congress must abide by the dictates of the Constitution even when it claims to be protecting against national security risks: “against [those] dangers ... as against others, the principle of the right to free speech is always the same." Abrams v. United States, 250 U.S. 616, 628 (1919) (Holmes, J., dissenting). Congress failed to do so here, and the Act should be enjoined. 11. Jurisdictional Statement Pursuant to Sections 3(a) and 3(b) of the Act, H.R. 815, div. H, 118th Cong., Pub. L. No. 118-50 (April 24, 2024), this Court has original (Page 7 of Total) 6

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 8 of 70 and exclusive jurisdiction over this challenge to the constitutionality of the Act. 2 A. 12. Background and Nature of Proceedings TikTok Is a Speech Platform Used by 170 Million Americans. Tik Tok is an online video entertainment platform designed to provide a creative and entertaining forum for users to express themselves and make connections with others over the Internet. More than 170 million Americans use TikTok every month, to learn about and share information on a range of topics from entertainment, to religion, to - politics. Content creators use the TikTok platform to express their opinions, discuss their political views, support their preferred political candidates, and speak out on today's many pressing issues, all to a global audience of more than 1 billion users. Many creators also use the 2 A copy of the Act is attached to this Petition as Exhibit A. Because this Petition does not involve a challenge to any agency action, it is not governed by Federal Rule of Appellate Procedure 15(a). Petitioners intend to file a separate motion regarding the procedures governing this original proceeding. Petitioners summarize the pertinent facts and claims below to facilitate this Court's review consistent with the practice of a case-initiating pleading in a court of original jurisdiction, but reserve their rights to present additional facts and arguments in due course. 7 (Page 8 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 9 of 70 platform to post product reviews, business reviews, and travel information and reviews. 13. In the United States, the TikTok platform is provided by Tik Tok Inc., a California-incorporated company that has its principal place of business in Culver City, California and offices in New York, San Jose, Chicago, and Miami, among other locations. TikTok Inc. has thousands of employees in the United States. Like many platforms owned by companies that operate globally, the global TikTok platform is supported not only by those employees, but also by employees of other ByteDance subsidiaries around the globe, including in Singapore, the United Kingdom, Brazil, Germany, South Africa, Australia, and China. Many of the global TikTok platform's functions are spread across different corporate entities and countries, and the global TikTok business is led by a leadership team based in Singapore and the United States. Like other U.S. companies, TikTok Inc. is governed by U.S. law. 14. Tik Tok Inc.'s ultimate parent company is ByteDance Ltd., a Cayman Islands-incorporated equity holding company. Byte Dance was founded in 2012 by Chinese entrepreneurs. Over time, the company sought funding to fuel growth, as is common in the technology sector, 8 (Page 9 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 10 of 70 which resulted in the issuance of additional equity and the dilution of existing shares. Today, approximately 58 percent of ByteDance Ltd. is owned by global institutional investors (such as BlackRock, General Atlantic, and Susquehanna International Group), 21 percent is owned by the company's founder (a Chinese national who lives in Singapore), and 21 percent is owned by employees including approximately 7,000 Americans. 15. ByteDance launched TikTok in May 2017 in over 150 countries, including the United States.³ Since its launch, TikTok has become one of the world's most popular applications, with over 1 billion users worldwide. As of January 2024, more than 170 million Americans use TikTok on a monthly basis. 16. Users primarily view content on TikTok through its "For You" page, which presents a collection of videos curated by TikTok's proprietary recommendation engine. The recommendation engine customizes each user's content feed based on how the user interacts with 3 Tik Tok was later relaunched in August 2018 following a transaction involving the company Musical.ly. See generally Petition for Review, Tik Tok Inc. v. CFIUS, No. 20-1444 (D.C. Cir. Nov. 10, 2020). 9 (Page 10 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 11 of 70 the content that the user watches. TikTok's popularity is based in large part on the effectiveness of the recommendation engine. The source code for TikTok's recommendation engine was originally developed by ByteDance engineers based in China, and the engine is customized for operations in TikTok's various global markets, including in the United States. TikTok is not offered in mainland China. 17. Aside from TikTok, ByteDance has developed and operates more than a dozen other online platforms and software applications for use in U.S. and international markets, including for content-sharing, video and music editing, e-commerce, gaming, and enterprise productivity. B. 18. The Government Previously Made Unlawful Attempts to Ban TikTok. Petitioners' efforts to address the U.S. government's asserted concerns regarding the TikTok platform date back to 2019. At that time, Petitioners began engaging with CFIUS, which had initiated a review of ByteDance Ltd.'s 2017 acquisition of Musical.ly, another Internet-based video-sharing platform. (Page 11 of Total) 10

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 12 of 70 19. Petitioners were in the early stages of engaging with CFIUS on a voluntary basis to address the government's concerns, when on August 6, 2020, President Trump abruptly issued an executive order purporting to ban TikTok under the International Emergency Economic Powers Act ("IEEPA”), 50 U.S.C. §§ 1701-08. See 85 Fed. Reg. 48,637 (the "Ban Order"). Two separate district courts preliminarily enjoined the Ban Order, concluding (among other things) that it exceeded the President's IEEPA authority. TikTok Inc. v. Trump, 490 F. Supp. 3d 73, 83 (D.D.C. 2020); TikTok Inc. v. Trump, 507 F. Supp. 3d 92, 112 (D.D.C. 2020); Marland v. Trump, 498 F. Supp. 3d 624, 641 (E.D. Pa. 2020). 20. Specifically, as these courts correctly recognized, the President's IEEPA authority "to deal with any unusual and extraordinary threat" to the nation “does not include the authority to regulate or prohibit, directly or indirectly ... [any] personal communication” or the importation or exportation “of any information or informational materials.” 50 U.S.C. § 1702(b)(1), (3). These restrictions on the President's IEEPA authority-which Congress expanded through multiple amendments to the statute were designed “to prevent the statute from running afoul of the First Amendment.” United States v. 11 (Page 12 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 13 of 70 Amirnazmi, 645 F.3d 564, 585 (3d Cir. 2011) (quotation marks omitted); see also Kalantari v. NITV, Inc., 352 F.3d 1202, 1205 (9th Cir. 2003) (IEEPA's limitations necessary “to prevent the executive branch from restricting the international flow of materials protected by the First. Amendment"); Marland, 498 F. Supp. 3d at 629 (same). 21. Looking to the foundational First Amendment principles codified in IEEPA's text and legislative history, these courts concluded that President Trump's efforts to ban TikTok violated the statute and raised "serious" constitutional questions (which were unnecessary to decide under the doctrine of constitutional avoidance). Tik Tok Inc., 507 F. Supp. 3d at 112 n.6; TikTok Inc., 490 F. Supp. 3d at 83 n.3. The courts granted the government's motions to voluntarily dismiss its appeals after President Biden withdrew the Ban Order. See Tik Tok Inc. v. Biden, No. 20-5302, 2021 WL 3713550 (D.C. Cir. July 20, 2021); Tik Tok Inc. v. Biden, No. 20-5381, 2021 WL 3082803 (D.C. Cir. July 14, 2021); Marland v. Trump, No. 20-3322, 2021 WL 5346749 (3d Cir. July 14, 2021). 22. Separately, acting on a CFIUS referral, President Trump on August 14, 2020 issued an order under Section 721 of the Defense Production Act, 50 U.S.C. § 4565, purporting to direct ByteDance to 12 (Page 13 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 14 of 70 divest from TikTok's U.S. business and U.S. user data. 85 Fed. Reg. 51,297 (the "Divestment Order"). On November 10, 2020, Petitioners petitioned this Court for review of the Divestment Order and underlying CFIUS actions, arguing, among other things, that the government lacked jurisdiction under the statute. See Petition for Review, TikTok Inc. v. CFIUS, No. 20-1444 (D.C. Cir. Nov. 10, 2020). That petition was held in abeyance in February 2021 on the parties' joint motion to allow the parties to negotiate a resolution. The government has filed status reports every 60 days since then, most recently on April 22, 2024. Those status reports have consistently reported that “[t]he parties continue to be involved in ongoing negotiations” and “[a] beyance continues to be appropriate.” See, e.g., Status Report, Tik Tok Inc. v. CFIUS, No. 20-1444 (D.C. Cir. Apr. 22, 2024). 23. Between January 2021 and August 2022, Petitioners and CFIUS engaged in an intensive, fact-based process to develop a National Security Agreement that would resolve the U.S. government's concerns about whether Chinese authorities might be able to access U.S. user data or manipulate content on TikTok, as well as resolve the pending CFIUS During that time, Petitioners and government officials dispute. 13 (Page 14 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 15 of 70 communicated regularly, often several times a week - including several - in-person meetings about the government's concerns and potential solutions. The result was an approximately 90-page draft National Security Agreement with detailed annexes embodying a comprehensive solution addressing the government's national security concerns. Notably, the draft National Security Agreement provided that all protected U.S. user data (as defined in the agreement) would be stored in the cloud environment of a U.S.-government-approved partner, Oracle Corporation, which would also review and vet the TikTok source code. 24. From Petitioners' perspective, all indications were that they were nearing a final agreement. After August 2022, however, CFIUS without explanation stopped engaging with Petitioners in meaningful discussions about the National Security Agreement. Petitioners repeatedly asked why discussions had ended and how they might be restarted, but they did not receive a substantive response. In March 2023, without providing any justification for why the draft National Security Agreement was inadequate, CFIUS insisted that Byte Dance would be required to divest the U.S. TikTok business. (Page 15 of Total) 14

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 16 of 70 25. Since March 2023, Petitioners have explained to CFIUS, in multiple written communications and in-person meetings, that a divestiture of the U.S. TikTok business from the rest of the integrated global Tik Tok platform and business of the sort now required by the Act is not feasible. CFIUS has never articulated any basis for disagreeing with that assessment, offering instead only a conclusory assertion that the reason ByteDance was not divesting was because it was simply unwilling to do so. The Act nonetheless incorporates precisely such an infeasible divestiture standard. C. 26. A Divestiture that Severs TikTok's U.S. Operations From the Rest of the Globally Integrated TikTok Business Is Not Commercially, Technologically, or Legally Feasible. The Act purports to allow Petitioners to avoid a ban by executing a "qualified divestiture." Sec. 2(c). But that alternative is illusory because, as Petitioners have repeatedly explained to CFIUS, the divestiture of the TikTok U.S. business and its severance from the globally integrated platform of which it is an integral part is not commercially, technologically, or legally feasible. (Page 16 of Total) 15

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 17 of 70 - 27. First, a standalone U.S. TikTok platform would not be commercially viable. TikTok and its competitors are globally integrated platforms where content created in one country is available to users in other countries. Indeed, a substantial part of TikTok's appeal is the richness of the international content available on the platform from global sporting events like the Olympics to international K-pop stars from South Korea, as well as videos created by U.S. creators and enjoyed by audiences worldwide. A divestment of the U.S. TikTok platform, without any operational relationship with the remainder of the global platform, would preclude the interoperability necessary to make international content seamlessly available in the U.S. market and vice versa. As a result, the U.S. TikTok platform would become an “island” where Americans would have an experience detached from the rest of the global platform and its over 1 billion users. Such a limited pool of content, in turn, would dramatically undermine the value and viability of the U.S. TikTok business.4 4 The contemplated qualified divestiture would also undercut the important role currently played by American voices in the global conversation ongoing on TikTok. 16 (Page 17 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 18 of 70 28. Second, precipitously moving all TikTok source code development from ByteDance to a new Tik Tok owner would be impossible as a technological matter. The platform consists of millions of lines of software code that have been painstakingly developed by thousands of engineers over multiple years. Although much of this code is basic infrastructure for running the global TikTok platform and has nothing at all to do with TikTok's recommendation algorithm, the statute requires that all of this code be wrested from Petitioners, so that there is no “operational relationship" between ByteDance and the new U.S. platform. Specifically, to comply with the law's divestiture requirement, that code base would have to be moved to a large, alternative team of engineers a team that does not exist and would have no understanding of the complex code necessary to run the platform. It would take years for an entirely new set of engineers to gain sufficient familiarity with the source code to perform the ongoing, necessary maintenance and development activities for the platform. Moreover, to keep the platform functioning, these engineers would need access to ByteDance software tools, which the Act prohibits. Such a fundamental rearchitecting is not - (Page 18 of Total) 17

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 19 of 70 remotely feasible on anything approaching the 270-day timeframe contemplated by the Act. 29. Third, the Chinese government has made clear that it would not permit a divestment of the recommendation engine that is a key to the success of TikTok in the United States. Like the United States,5 China regulates the export of certain technologies originating there. China's export control rules cover “information processing technologies” such as "personal interactive data algorithms.”6 China's official news agency has reported that under these rules, any sale of recommendation algorithms developed by engineers employed by ByteDance subsidiaries in China, including for TikTok, would require a government license. 5 For example, the U.S. Department of Commerce has issued restrictions on the export to China of advanced chips that can be used to train artificial intelligence models. E.g., Implementation of Additional Export Controls: Certain Advanced Computing Items; Supercomputer and Semiconductor End Use; Updates and Corrections, 88 Fed. Reg. 73458 (Oct. 25, 2023) (to be codified at 15 C.F.R. § 732.2 et seq.). 6 See Karen M. Sutter, Cong. Rsch. Serv., IN11524, China Issues New Export Control Law and Related Policies 2 (2020). 7 Paul Mozur, Raymond Zhong & David McCabe, Tik Tok Deal Is Complicated by New Rules From China Over Tech Exports, N.Y. Times (Aug. 29, 2020), https://perma.cc/L6RB-CTT9. 18 (Page 19 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 20 of 70 China also enacted an additional export control law that "gives the Chinese government new policy tools and justifications to deny and impose terms on foreign commercial transactions."8 China adopted these enhanced export control restrictions between August and October 2020, shortly after President Trump's August 6, 2020 and August 14, 2020 executive orders targeting TikTok. By doing so, the Chinese government clearly signaled that it would assert its export control powers with respect to any attempt to sever TikTok's operations from ByteDance, and that any severance would leave TikTok without access to the recommendation engine that has created a unique style and community that cannot be replicated on any other platform today. D. 30. The Act Bans TikTok and Other Byte Dance Applications. On April 24, 2024, the President signed the Protecting Americans from Foreign Adversary Controlled Applications Act. 31. The Act prohibits, on pain of draconian penalties, “online mobile application store[s]" and "internet hosting services" from servicing "foreign adversary controlled application[s]" within the United States. 8 Sutter, supra n.6. 19 (Page 20 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 21 of 70 See Sec. 2(a), 2(d)(1)(A). This includes the "distribution, maintenance, or updating" of a covered application through an online marketplace. Sec. 2(a)(1). 32. Section 2(g) (3) creates two classes of "foreign adversary controlled applications" covered by the Act. 33. The first class singles out only one corporate group: "Byte Dance[] Ltd.,” “TikTok,” their “subsidiar[ies] or successor[s]" that are "controlled by a foreign adversary," or any entity "owned or controlled" by the aforementioned.9 The Act deems any application. operated by these entities a “foreign adversary controlled application," without any finding about why any particular application much less - - every application operated by these entities should be so designated. See Sec. 2(g)(3)(A). 9 “TikTok” is a platform, not a legal entity. Petitioners assume that Congress intended this provision to be a reference to TikTok Inc., and further reserve their rights to amend this Petition to include additional Tik Tok entities to the extent the government takes the position that other entities are covered by this reference. In any event, TikTok Inc. is covered as an entity “owned or controlled" by ByteDance Ltd. 20 (Page 21 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 22 of 70 34. The second class creates a discretionary process by which the President can designate other companies whose applications will also effectively be banned. Under these provisions, the President may designate an application as a "foreign adversary controlled application" if several qualifications are met: a. Covered Company. The website or application is operated directly or indirectly by a "covered company" - i.e., a company that operates a website or application that permits users to share content and has at least 1 million monthly active users. See Sec. 2(g)(2)(A). b. Controlled by a Foreign Adversary. The "covered company" operating the website or application must also be "controlled by a foreign adversary," meaning it is "headquartered in, has its principal place of business in, or is organized under the laws" of a "foreign adversary country," which currently includes China, North Korea, Russia, and Iran. Sec. 2(g)(1)(A), (g)(4); see also 10 U.S.C. § 4872(d)(2). A company may also be "controlled by a foreign adversary" if persons domiciled in any of the 21 (Page 22 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 23 of 70 (Page 23 of Total) specified countries (i.e., China, Iran, Russia, or North Korea) directly or indirectly own at least 20 percent of the company. Sec. 2(g)(1)(B). c. Not Exempt under Sec. 2(g)(2)(B). But Congress specifically exempted from the term “covered company" any "entity that operates" a website or application "whose primary purpose is to allow users to post product reviews, business reviews, or travel information and reviews." An entity that operates a single website or application of this nature thus cannot be a “covered company,” even if it is "controlled by a foreign adversary," poses a significant national security risk, and separately operates an application whose primary purpose is anything other than allowing users to post reviews. Sec. 2(g)(2)(B). d. Presidential Determination, Notice and Report, and Judicial Review. Finally, the President must determine that such a company presents “a significant threat to the national security of the United States." Sec. 2(g)(3)(B)(ii). Before making such a determination, the President must 22

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 24 of 70 issue public notice proposing the determination and then provide a public report to Congress describing "the specific national security concern involved," supplemented by a classified annex, and also explain "what assets would need to be divested to execute a qualified divestiture." Id. These presidential determinations are then subject to judicial review. Sec. 3(a). 35. Section 2(c) exempts a "foreign adversary controlled application[]" from the Act's prohibitions if the company that operates the application executes a “qualified divestiture." Sec. 2(c). The President must determine that such divestiture would (1) "result in the relevant covered company no longer being controlled by a foreign adversary," and (2) “preclude[] the establishment or maintenance of any operational relationship" between the application's U.S. operations and any formerly affiliated entities that are controlled by a foreign adversary, including "any cooperation with respect to the operation of a content. recommendation algorithm." Sec. 2(c), (g) (6). As noted above, the Act's broad definition of "controlled by a foreign adversary" includes, among other things, any entity organized under the laws of a "foreign adversary 23 (Page 24 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 25 of 70 country," or any entity in which a foreign person domiciled in a foreign adversary country holds at least a 20 percent ownership stake. Sec. 2(g)(1), (3)(B)(i), (4). 36. The prohibition on providing Internet hosting and mobile application store services to TikTok and other ByteDance applications. takes effect 270 days after enactment. Sec. 2(a)(2)(A). The President may extend this deadline, but only for 90 days maximum, and only if the President certifies to Congress that a path to executing a qualified divestiture has been identified, evidence of significant progress toward executing that qualified divestiture has been produced, and the relevant binding legal agreements to enable execution of the qualified divestiture are in place. 37. "Before the date on which [this] prohibition" takes effect, Petitioners are required to provide, upon request by any U.S. user of any of their applications, “all the available data related to the account of such user with respect to such application." Sec. 2(b).10 10 Because Section 2(b)'s data portability requirement applies "[b]efore" the prohibition under Section 2(a) takes effect, it cannot be "given effect" without Section 2(a) for purposes of Section 2(e)(1) of the Act, which provides that "[i]f any provision of this section or the application of this 24 (Page 25 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 26 of 70 38. Because the Act lacks any legislative findings or a statement of purpose, Petitioners and the more than 170 million American monthly users of TikTok are left to scrutinize statements from individual Members of Congress and other sources to try to discern any purported justification for this extraordinary intrusion on free speech rights. Based on these sources, it appears at least some Members of Congress sought to address "two threats" that could emerge from foreign ownership of communications platforms. 11 39. First, they may have sought to protect U.S. users' “data security."12 According to the House Committee Report for an earlier version of the Act, mobile applications, including those that are not section to any person or circumstance is held invalid, the invalidity shall not affect the other provisions or applications of this section that can be given effect without the invalid provision or application." Because Section 2(a) violates the Constitution for the reasons set forth herein, Section 2(b) is accordingly "not operative in the absence of the unconstitutional provision.” Barr v. Am. Ass'n of Pol. Consultants, Inc., 140 S. Ct. 2335, 2352 n.9 (2020). 11 Jane Coaston, What the Tik Tok Bill Is Really About, According to a Leading Republican, N.Y. Times (Apr. 1, 2024), https://perma.cc/BL32- 786X (quoting the Act's original sponsor, Rep. Mike Gallagher). 12 Id. (Page 26 of Total) 25

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 27 of 70 controlled by foreign adversaries, can “collect vast amounts of data on Americans."13 The House Committee Report expressed a concern that such data could be used by a foreign adversary to "conduct espionage campaigns," such as by tracking specific individuals. 14 40. Second, others in Congress appear to have been motivated by a "greater concern": an alleged "propaganda threat." 15 One proponent of the Act stated that communications applications could be used to "push misinformation, disinformation, and propaganda on the American public."16 Another supporter claimed in the House Select Committee press release accompanying the bill's introduction that “[TikTok] is ... poisoning the minds of our youth every day on a massive scale."17 13 H.R. Comm. on Energy & Com., Protecting Americans from Foreign Adversary Controlled Applications Act, H.R. Rep. No. 118-417 at 2 (2024) (hereinafter the "House Committee Report"). 14 Id. 15 Coaston, supra n.11 (quoting Rep. Gallagher). 16 House Committee Report at 2. 17 Press Release, U.S. House Select Comm. on Strategic Competition Between the U.S. and the Chinese Communist Party, Gallagher, Bipartisan Coalition Introduce Legislation to Protect Americans From Foreign Adversary Controlled Applications, Including TikTok (Mar. 5, 2024), https://perma.cc/KC5T-6AX3. (Page 27 of Total) 26

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 28 of 70 E. Congress Disregarded Alternatives to Banning TikTok, Such as the National Security Measures Petitioners Negotiated with the Executive Branch. 41. Petitioners have demonstrated a commitment to addressing both of those concerns without the need to resort to the drastic, unconstitutional step of shuttering one of the most widely used forums for speech in the United States. The 90-page draft National Security Agreement that Petitioners developed with Petitioners developed with CFIUS would, if implemented, provide U.S. TikTok users with protections more robust than those employed by any other widely used online platform in the industry. 42. The draft National Security Agreement contains several means of ensuring data security without banning TikTok. All protected U.S. user data (as defined in the National Security Agreement) would be safeguarded in the United States under a special corporate structure: TikTok U.S. Data Security (a new subsidiary of Tik Tok Inc.). A special board, with Security Directors whose appointment would be subject to the U.S. government's approval, would oversee TikTok U.S. Data Security, and in turn exclude ByteDance and all of its other subsidiaries and affiliates from such responsibilities. Further separation between the 27 (Page 28 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 29 of 70 U.S. TikTok business and Byte Dance subsidiaries and affiliates, including TikTok in the rest of the world, would be achieved by appointing a U.S.-government-approved Security Director to the board of Tik Tok Inc. Protected U.S. user data would be stored in the cloud environment of a U.S.-government-approved partner, Oracle Corporation, with access to such data managed by TikTok U.S. Data Security. 43. The draft Agreement would also protect against the concern about content manipulation and propaganda. Multiple layers of protection address concerns related to content available on the TikTok platform, including ensuring that all content moderation - both human and algorithmic ➖ would be subject to third-party verification and monitoring. The concern about content manipulation would also be addressed by securing all software code through Oracle Corporation, a U.S. trusted technology provider. The Tik Tok U.S. platform and application would be deployed through the Oracle cloud infrastructure and subject to source code review and vetting by Oracle with another U.S.-government-approved third party responsible for conducting security inspections. As part of this process, Oracle and third parties 28 (Page 29 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 30 of 70 approved by CFIUS would conduct independent inspections of the Tik Tok recommendation engine. 44. The draft Agreement also includes strict penalties for noncompliance, including a "shut-down option," giving the government the authority to suspend TikTok in the United States in response to specified acts of noncompliance. The Agreement also provides significant monetary penalties and other remedies for noncompliance. 45. Although the government has apparently abandoned the draft National Security Agreement, Petitioners have not. TikTok Inc. has begun the process of voluntarily implementing the National Security Agreement's provisions to the extent it can do so without the U.S. government's cooperation, including by incorporating and staffing the TikTok U.S. Data Security entity, and by partnering with Oracle Corporation on the migration of the U.S. platform and protected U.S. user data to Oracle's cloud environment. 46. To date, Petitioners have spent more than $2 billion to implement these measures and resolve the very concerns publicly expressed by congressional supporters of the Act all without the overbroad and unconstitutional method of an outright ban. 29 (Page 30 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 31 of 70 Grounds On Which Relief Is Sought Petitioners seek review of the constitutionality of the Act on grounds that include, without limitation, the following. Ground 1: Violation of the First Amendment 47. The First Amendment to the U.S. Constitution provides that "Congress shall make no law. . . abridging the freedom of speech." U.S. Const., amend. I. 48. By banning all online platforms and software applications offered by "TikTok" and all ByteDance subsidiaries, Congress has made a law curtailing massive amounts of protected speech. Unlike broadcast television and radio stations, which require government licenses to operate because they use the public airwaves, the government cannot, consistent with the First Amendment, dictate the ownership of newspapers, websites, online platforms, and other privately created. speech forums. 49. Indeed, in the past, Congress has recognized the importance of protecting First Amendment rights, even when regulating in the interest of national security. For example, Congress repeatedly amended IEEPA which grants the President broad authority to address national 30 (Page 31 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 32 of 70 emergencies that pose "unusual and extraordinary threat[s]" to the country to expand protections for constitutionally protected materials. 50 U.S.C. §§ 1701-02. Accordingly, under IEEPA, the President does not have the authority to even indirectly regulate "personal communication" or the importation or exportation "of any information or informational materials,” id. § 1702(b)(1), (3) limitations that are necessary "to prevent the statute from running afoul of the First Amendment," Amirnazmi, 645 F.3d at 585. Yet Congress has attempted to sidestep these statutory protections aimed at protecting Americans' constitutional rights, preferring instead to simply enact a new statute that tries to avoid the constitutional limitations on the government's existing statutory Those statutory protections were evidently seen as an impediment to Congress's goal of banning TikTok, so the Act dispensed authority. with them. 50. The Act's alternative to a ban a so-called “qualified - - divestiture" is illusory to the point of being no alternative at all. As explained above, divesting TikTok Inc.'s U.S. business and completely severing it from the globally integrated platform of which it is a part is not commercially, technologically, or legally feasible. 31 (Page 32 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 33 of 70 51. The Act will therefore have the effect of shutting down TikTok in the United States, a popular forum for free speech and expression used by over 170 million Americans each month. And the Act will do so based not on any proof of a compelling interest, but on speculative and analytically flawed concerns about data security and content manipulation concerns that, even if grounded in fact, could be - addressed through far less restrictive and more narrowly tailored means. 52. Petitioners' protected speech rights. The Act burdens Tik Tok Inc.'s First Amendment rights in addition to the free speech - rights of millions of people throughout the United States in two ways. - 53. First, Petitioner TikTok Inc. has a First Amendment interest in its editorial and publishing activities on TikTok. See Hurley v. Irish- Am. Gay, Lesbian & Bisexual Grp. of Bos., 515 U.S. 557, 570 (1995). TikTok “is more than a passive receptacle or conduit for news, comment, and advertising" of others; TikTok Inc.'s "choice of material" to recommend or forbid “constitute[s] the exercise of editorial control and judgment" that is protected by the First Amendment. Miami Herald Pub. Co. v. Tornillo, 418 U.S. 241, 258 (1974); see also Alario v. Knudsen, (Page 33 of Total) 32

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 34 of 70 - F. Supp. 3d, 2023 WL 8270811, at *6 (D. Mont. Nov. 30, 2023) (recognizing Tik Tok Inc.'s First Amendment editorial rights). 54. As the government itself has acknowledged, “[w]hen [social media] platforms decide which third-party content to present and how to present it, they engage in expressive activity protected by the First Amendment because they are creating expressive compilations of speech." Br. for United States as Amicus Curiae at 12-13, Moody v. NetChoice LLC, No. 22-277 (U.S.), 2023 WL 8600432; see also id. at 18- 19, 25-26. 55. Second, Tik Tok Inc. is among the speakers whose expression the Act prohibits. TikTok Inc. uses the TikTok platform to create and share its own content about issues and current events, including, for example, its support for small businesses, Earth Day, and literacy and education. 18 When TikTok Inc. does so, it is engaging in core speech protected by the First Amendment. See Sorrell v. IMS Health Inc., 564 18 Tik Tok (@tiktok), TikTok, https://www.tiktok.com/t/ZTL9QsTYs/ (last visited May 6, 2024); TikTok (@tiktok), TikTok, https://www.tiktok.com/t/ZTL9QbSHv/ (last visited May 6, 2024); TikTok (@tiktok), TikTok, https://www.tiktok.com/t/ZTL9QXE7R/ (last visited May 6, 2024). (Page 34 of Total) 33

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 35 of 70 U.S. 552, 570 (2011); NetChoice, LLC v. Att'y Gen., Fla., 34 F.4th 1196, 1210 (11th Cir. 2022), cert. granted, 144 S. Ct. 478 (2023). The Act precludes TikTok Inc. from expressing itself over that platform. 56. Even if the U.S. TikTok platform could be divested, which it cannot for the reasons explained above, TikTok Inc.'s protected speech rights would still be burdened. Because the Act appears to conclusively determine that any application operated by "TikTok" - a term that — Congress presumably meant to include Tik Tok Inc. is a foreign adversary controlled application, Sec. 2(g)(3)(A), the President appears to lack the power to determine that a TikTok Inc.-owned application is "no longer being controlled by a foreign adversary" and has no “operational relationship" with “formerly affiliated entities that are controlled by a foreign adversary," Sec. 2(g)(6)(A) & (B). The Act therefore appears to conclusively eliminate TikTok Inc.'s ability to speak through its editorial and publishing activities and through its own. account on the TikTok platform. 57. For similar reasons, the Act burdens the First Amendment rights of other ByteDance subsidiaries to reach their U.S. user audiences, (Page 35 of Total) 34

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 36 of 70 since those companies are likewise prohibited from speaking and engaging in editorial activities on other ByteDance applications. 58. The Act is subject to strict scrutiny. The Act's restrictions on Petitioners' First Amendment rights are subject to strict scrutiny for three independent reasons. 59. First, the Act represents a content- and viewpoint-based restriction on protected speech. The Act discriminates on a content basis because it exempts platforms "whose primary purpose" is to host specific types of content: "product reviews, business reviews, or travel information and reviews.” Sec. 2(g)(2)(B). The Act thus “distinguish[es] favored speech" - i.e., speech concerning travel information and business reviews "from disfavored speech" ―i.e., all other types of - speech, including particularly valuable speech like religious and political content. Turner Broad. Sys., Inc. v. FCC, 512 U.S. 622, 643 (1994). 60. The Act also discriminates on a viewpoint basis because it appears to have been enacted at least in part because of concerns over the viewpoints expressed in videos posted on TikTok by users of the platform. For example, the House Committee Report asserted, without supporting evidence, that Tik Tok "can be used by [foreign adversaries] to 35 (Page 36 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 37 of 70 push misinformation, disinformation, and propaganda on the American public" 19 a concern that in any event could be raised about any platform for user-generated content. See infra ¶¶82, 87. Similarly, Rep. Raja Krishnamoorthi, who co-sponsored the Act, expressed the unsubstantiated concern that “the platform continued to show dramatic differences in content relative to other social media platforms."20 61. Second, the Act discriminates between types of speakers. As explained above, TikTok Inc. is a protected First Amendment speaker with respect to the TikTok platform. The Act facially discriminates between Tik Tok Inc. and other speakers depending on the "primary purpose” of the platforms they operate. Any application offered by Petitioners is automatically deemed a “foreign adversary controlled application,” without any exclusions or exceptions. Sec. 2(g)(3)(A). By contrast, any other company's application can be deemed a "foreign adversary controlled application” only if the company does not operate a 19 House Committee Report at 2. 20 Sapna Maheshwari, David McCabe & Annie Karni, House Passes Bill to Force Tik Tok Sale From Chinese Owner or Ban the App, N.Y. Times (Mar. 13, 2024), https://perma.cc/Z7UE-WYH6. (Page 37 of Total) 36

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 38 of 70 website or application "whose primary purpose is to allow users to post product reviews, business reviews, or travel information and reviews." Sec. 2(g)(2)(B). The Act thus favors speakers that do offer such websites or applications over speakers that do not. 62. Moreover, the Act singles out TikTok Inc. and other subsidiaries of ByteDance for unique disfavor in other ways. Whereas other companies with ownership in a country deemed a "foreign adversary" become subject to the Act's restrictions only upon a presidential determination that the company poses "a significant threat to the national security of the United States,” Sec. 2(g)(3)(B), ByteDance Ltd. and its subsidiaries are automatically subject to the Act's draconian restrictions by fiat, Sec. 2(g)(3)(A). The standard and process that the Act specifies for every other company likely fall short of what is required. by the First Amendment and other applicable constitutional protections, but TikTok Inc. and ByteDance have been singled out for a dramatically different, even more clearly unconstitutional regime with no public notice, no process for a presidential determination that there is a significant national security threat, no justification of that determination by a public report and submission of classified evidence to Congress, and 37 - (Page 38 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 39 of 70 no judicial review for statutory and constitutional sufficiency based on the reasons set forth in the presidential determination. The Act also draws a speaker-based distinction insofar as it specifically names Byte Dance Ltd. and TikTok, and also exempts applications with fewer than 1 million monthly users (except if those applications are operated by ByteDance Ltd. or TikTok). Sec. 2(g)(2)(A)(ii), (3)(A). 63. A statutory restriction targeting specific classes of speakers is subject to strict scrutiny. See United States v. Playboy Ent. Grp., Inc., 529 U.S. 803, 812 (2000) ("Laws designed or intended to suppress or restrict the expression of certain speakers contradict basic First Amendment principles."). And that is especially true when, as here, the Act singles out Petitioners by name for uniquely disfavored treatment and congressional statements indicate that the Act targets Petitioners in part because of concerns about the content on TikTok. Because the Act "target[s]" both "speakers and their messages for disfavored treatment,” strict scrutiny review is required. Sorrell, 564 U.S. at 565; see also Turner, 512 U.S. at 658-60. 64. Third, the Act is subject to strict scrutiny as an unlawful prior restraint. The Supreme Court has "consistently" recognized in a "long 38 (Page 39 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 40 of 70 line" of cases that government actions that “deny use of a forum in advance of actual expression" or forbid “the use of public places [for plaintiffs] to say what they wanted to say" are prior restraints. Se. Promotions, Ltd. v. Conrad, 420 U.S. 546, 552-53 (1975). “[P]rior restraints on speech and publication are the most serious and the least. tolerable infringement on First Amendment rights." Nebraska Press Ass'n v. Stuart, 427 U.S. 539, 559 (1976). The Act suppresses speech in advance of its actual expression by prohibiting all U.S. TikTok users including Petitioner Tik Tok Inc. - from communicating on the platform. See Backpage.com, LLC v. Dart, 807 F.3d 229 (7th Cir. 2015) (defendant's conduct restricting the operator of classified advertising website was a prior restraint); Org. for a Better Austin v. Keefe, 402 U.S. 415, 418–19 (1971) (ban on distributing leaflets a prior restraint); U.S. WeChat Users All. v. Trump, 488 F. Supp. 3d 912, 926 (N.D. Cal. 2020) (ban on communications application a prior restraint). The same is true of other Byte Dance subsidiaries and their platforms. Such restrictions “bear[] a heavy presumption against [their] constitutional validity." Se. Promotions, 420 U.S. at 558. (Page 40 of Total) 39

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 41 of 70 65. The Act fails strict scrutiny because it does not further a compelling interest. Strict scrutiny “requires the Government to prove that the restriction [1] furthers a compelling interest and [2] is narrowly tailored to achieve that interest." Reed v. Town of Gilbert, 576 U.S. 155, 171 (2015) (numerical alterations added). "If a less restrictive alternative would serve the Government's purpose, the legislature must use that alternative." Playboy, 529 U.S. at 813. The Act fails on both counts. 66. The Act does not further a compelling interest. To be sure, national security is a compelling interest, but the government must show that the Act furthers that interest. To do so, the government "must do more than simply posit the existence of the disease sought to be cured." Turner, 512 U.S. at 664 (plurality op.). Rather, it “must demonstrate that the recited harms are real, not merely conjectural, and that the regulation will in fact alleviate these harms in a direct and material way." Id. 67. Congress itself has offered nothing to suggest that the TikTok platform poses the types of risks to data security or the spread of foreign propaganda that could conceivably justify the Act. The Act is devoid of 40 (Page 41 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 42 of 70 any legislative findings, much less a demonstration of specific harms that Tik Tok supposedly poses in either respect, even though the platform was first launched in 2017. 68. The statements of congressional committees and individual Members of Congress during the hasty, closed-door legislative process preceding the Act's enactment confirm that there is at most speculation, not "evidence,” as the First Amendment requires. Instead of setting out evidence that TikTok is actually compromising Americans' data security by sharing it with the Chinese government or spreading pro-China propaganda, the House Committee Report for an earlier version of the Act relies repeatedly on speculation that Tik Tok could do those things. See, e.g., House Committee Report at 6 (TikTok could “potentially [be] allowing the CCP 'to track the locations of Federal employees and contractors") (emphasis added) (quoting Exec. Order 13,942, 85 Fed. Reg. 48637, 48637 (Aug. 6, 2020)); id. at 8 (discussing "the possibility that the [CCP] could use [TikTok] to control data collection on millions of users") (emphasis added); id. ("Tik Tok has sophisticated capabilities that create the risk that [it] can ……. suppre[ss] statements and news that the PRC deems negative") (emphasis added). Speculative risk of harm is simply 41 (Page 42 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 43 of 70 not enough when First Amendment values are at stake. These risks are even more speculative given the other ways that the Chinese government could advance these asserted interests using a variety of intelligence tools and commercial methods. See infra 85–87. 69. The conjectural nature of these concerns are further underscored by President Biden's decision to continue to maintain a Tik Tok account for his presidential campaign even after signing the Act into law. 21 Congressional supporters of the Act have also maintained campaign accounts on TikTok. 22 This continued use of TikTok by President Biden and Members of Congress undermines the claim that the platform poses an actual threat to Americans. 70. Further, even if the government could show that TikTok or another ByteDance-owned application "push[es] misinformation, disinformation, and propaganda on the American public," House 21 Monica Alba, Sahil Kapur & Scott Wong, Biden Campaign Plans to Keep Using Tik Tok Through the Election, NBC News (Apr. 24, 2024), https://perma.cc/QPQ5-RVAD. 22 Tom Norton, These US Lawmakers Voted for Tik Tok Ban But Use It Themselves, Newsweek (Apr. 17, 2024), https://perma.cc/AQ5F-N8XQ. At least one Member created a TikTok account after the Act was enacted. See https://perma.cc/L3GT-7529. (Page 43 of Total) 42

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 44 of 70 Committee Report at 2, the government would still lack a compelling interest in preventing Americans from hearing disfavored speech. generated by TikTok users and shared on the platform just because the government considers it to be foreign "propaganda." See Lamont v. Postmaster Gen. of U.S., 381 U.S. 301, 305 (1965). 71. The Act also offers no support for the idea that other applications operated by subsidiaries of ByteDance Ltd. pose national security risks. Indeed, the legislative record contains no meaningful discussion of any ByteDance-owned application other than TikTok― let alone evidence “proving” that those other applications pose such risks. Reed, 576 U.S. at 171. 72. - The Act also provides neither support nor explanation for subjecting Petitioners to statutory disqualification by legislative fiat while providing every other platform, and users of other platforms, with a process that includes a statutory standard for disqualification, notice, a reasoned decision supported by evidence, and judicial review based on those specified reasons. Only Petitioners are subjected to a regime that has no notice and no reasoned decision supported by evidence - opening the door to, among other things, post-hoc arguments that may not have 43 (Page 44 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 45 of 70 been the basis for the government action. The Supreme Court recently explained that the requirement of a "reasoned explanation" is "meant to ensure that [the government] offer[s] genuine justifications for important decisions, reasons that can be scrutinized by courts and the interested public. Accepting contrived reasons would defeat the purpose of the enterprise." Dep't of Com. v. New York, 139 S. Ct. 2551, 2576 (2019). Depriving Petitioners of those protections imposes a dramatically heavier burden on the free speech rights of Petitioners and TikTok users that is wholly unjustified and certainly not supported by a compelling interest. The Act also fails strict scrutiny because it is not narrowly tailored. "Even where questions of allegedly urgent national security. . . are concerned," the government must show that "the evil that would result from the [restricted speech] is both great and certain and cannot be mitigated by less intrusive measures.” CBS, Inc. v. Davis, 510 U.S. 1315, 1317 (1994). To satisfy narrow tailoring, the Act must represent the least restrictive means to further the government's asserted data security and propaganda interests, Sable Commc'ns of Cal., Inc. v. FCC, 492 U.S. 115, 126 (1989), and be neither over- nor under- 73. (Page 45 of Total) 44

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 46 of 70 inclusive, Ark. Writers' Project, Inc. v. Ragland, 481 U.S. 221, 232 (1987). The Act fails in each of these respects. 74. The Act opts for a wholesale prohibition on Petitioners offering online applications in lieu of a multitude of less restrictive measures it could have taken instead. As discussed above, Petitioners have been involved in negotiations with CFIUS since 2019 over a package of measures that would resolve the government's concerns about data security and purported propaganda related to TikTok. The terms of that negotiated package are far less restrictive than an outright ban. The negotiations have resulted in the draft National Security Agreement, which Tik Tok Inc. is already in the process of voluntarily implementing to the extent it can do so without government action. That initiative includes a multi-billion-dollar effort to create a new TikTok U.S. subsidiary devoted to protecting U.S. user data and have U.S.-based Oracle Corporation store protected U.S. TikTok user data in the United States, run the TikTok recommendation system for U.S. users, and inspect TikTok's source code for security vulnerabilities. 75. If executed by the government, the National Security Agreement would also give CFIUS a "shut-down option" to suspend 45 (Page 46 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 47 of 70 Tik Tok in the United States in response to specified acts of noncompliance. The government has never meaningfully explained why the National Security Agreement (a far less restrictive alternative to an outright, total ban) is insufficient to address its stated concerns about data security and propaganda. 76. Even if the government's dissatisfaction with the draft. National Security Agreement were valid (despite the government never explaining why the agreement that the government itself negotiated is unsatisfactory), the CFIUS process in in which Petitioners have participated in good faith is geared toward finding any number of other less restrictive alternatives to an outright, total ban. The CFIUS member agencies could return to working with Petitioners to craft a solution that is tailored to meet the government's concerns and that is commercially, technologically, and legally feasible. Yet the government has not explained why the CFIUS process is not a viable alternative. 77. There are also a wide range of other less restrictive measures that Congress could have enacted. While many of these measures are themselves unjustified as applied to Petitioners, they nevertheless. illustrate that the Act does not select the least restrictive means to 46 (Page 47 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 48 of 70 further the national security goals that appear to have motivated it. For example, Congress could have addressed some members' stated concern about Tik Tok allegedly "track[ing] the locations of Federal employees and contractors" 23 by expanding the existing ban on government-owned devices to cover personal devices of federal employees and contractors. Or Congress could have enacted legislation to regulate TikTok's access to measures the Department of certain features on users' devices Homeland Security identified in 2020 as potential mitigations to "reduce the national security risks associated with" TikTok.24 78. Of course, Congress could also have decided not to single out a single speech platform (TikTok) and company (ByteDance Ltd.), and instead pursued any number of industry-wide regulations aimed at addressing the industry-wide issues of data security and content integrity. Congress could have enacted a data protection law governing transfers of Americans' sensitive data to foreign countries, similar to the 23 House Committee Report at 6. 24 Cybersecurity and Infrastructure Agency, Critical Infrastructure Security and Resilience Note, Appendix B: Department of Homeland Security Tik Tok and WeChat Risk Assessment 4 (Sept. 2, 2020). 47 (Page 48 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 49 of 70 strategy President Biden is currently pursuing through executive - the order. 25 Indeed, Congress did enact such a data-transfer law similarly named "Protecting Americans' Data from Foreign Adversaries Act of 2024" as the very next division of the legislation that contains the Act. Yet it chose to prohibit only “data broker[s]” from “mak[ing] available personally identifiable sensitive data of a United States. individual to any foreign adversary country or ... any entity that is controlled by a foreign adversary." H.R. 815, div. I, § 2(a), 118th Cong., Pub. L. No. 118-50 (Apr. 24, 2024). 79. There are also models for industry-wide regulation that Congress could have followed from other jurisdictions. For example, the European Union's Digital Services Act requires certain platforms to make disclosures about their content-moderation policies and to provide regulators and researchers with access to their data so those researchers can assess if the platforms are systemically promoting or suppressing 25 See Exec. Order 14, 117, 89 Fed. Reg. 15421 (Mar. 1, 2024). 48 (Page 49 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 50 of 70 content with particular viewpoints. 26 Congress pursued none of these alternatives. 80. Congress did not even provide Petitioners with the process and fact-finding protections that the Act extends to all other companies -protections which themselves likely fall short of what the Constitution mandates. Other companies receive prior notice, followed by a presidential determination of (and public report on) the national security threat posed by the targeted application, and the submission to Congress. of classified evidence supporting that determination, Sec. 2(g)(3)(B), which then is subject to judicial review based on the actual reasons for the decision, not post hoc rationalizations. 81. Because Congress failed to try any of these less restrictive measures, or at a minimum to explain why these alternatives would not address the government's apparent concerns, the Act is not narrowly tailored. 82. The Act independently fails strict scrutiny because it is both under- and over-inclusive. The Act is under-inclusive because it 26 EU Reg. 2022/2065 arts. 15, 40(4), 42(2). 49 (Page 50 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 51 of 70 ignores the many ways in which other companies. - both foreign and domestic can pose the same risks to data security and promotion of misinformation supposedly posed by Petitioners. The government "cannot claim" that banning some types of foreign owned applications is "necessary" to prevent espionage and propaganda “while at the same time" allowing other types of platforms and applications that may "create the same problem.” Reed, 576 U.S. at 172. Put differently, the Act's “[u]nderinclusiveness raises serious doubts about whether the government is in fact pursuing the interest it invokes, rather than disfavoring a particular speaker or viewpoint.” Brown v. Ent. Merchants Ass'n, 564 U.S. 786, 802 (2011). 83. Most glaringly, the Act applies only to Petitioners and certain other platforms that allow users to generate and view "text, images, videos, real-time communications, or similar content.” Sec. 2(g)(2)(A). The Act's coverage is thus triggered not by whether an application. collects users' data, but whether it shows them “content." Accordingly, there is no necessary relationship between the Act's scope and Congress's apparent concern with risks to Americans' data security, which could (Page 51 of Total) 50

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 52 of 70 equally be posed by personal finance, navigation, fitness, or many other types of applications. 84. The Act also singles out Petitioners by exempting all other companies that operate any website or application "whose primary purpose is to allow users to post product reviews, business reviews, or travel information and reviews." Sec. 2(g)(2)(B). But the Act does not explain why such applications, when (i) “foreign adversary controlled” under the Act's broad definition; and (ii) determined by the President to be a significant national security threat, could not likewise be used to collect data from Americans such as Americans' location information - or to spread misinformation. Nor does the Act explain why an entire company presents no threat simply because it operates a single website or application the “primary purpose” of which is posting “product reviews, business reviews, or travel information and reviews." Sec. 2(g)(2)(B). The Act's differential treatment of this favored category of websites and applications also disregards the fact that there is voluminous content on Tik Tok containing product reviews, business reviews, and travel information and reviews. Yet TikTok and all ByteDance applications are ineligible for this exclusion. 51 (Page 52 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 53 of 70 85. More broadly, the Act ignores the reality that much of the data collected by Tik Tok is no different in kind from the data routinely collected by other applications and sources in today's online world, including by American companies like Google, Snap, and Meta. The Act also ignores that foreign countries, including China, can obtain such information on Americans in other ways such as through open-source research and hacking operations. 86. Likewise, the House Committee Report on an earlier version of the Act speculates that allowing source code development in China "potentially exposes U.S. users to malicious code, backdoor vulnerabilities, surreptitious surveillance, and other problematic activities tied to source code development."27 But those supposed risks arise for each of the many American companies that employ individuals in China to develop code. The Act, however, does not seek to regulate, much less prohibit, all online applications offered by companies that have offices in China or that otherwise employ Chinese nationals as software developers. 28 27 House Committee Report at 5. 28 See, e.g., Karen Freifeld & Jonathan Stempel, Former Google Engineer 52 (Page 53 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 54 of 70 87. Nor does the Act seek to cut off numerous other ways that Americans could be exposed to foreign propaganda. For instance, the Act leaves foreign nationals (and even adversarial governments themselves) free to operate cable television networks in the United States, spread propaganda through accounts on other online platforms that enable the sharing of user-generated content, or distribute copies of state-run newspapers physically or over the Internet (including by software applications) in the United States. 29 Indicted for Stealing AI Secrets to Aid Chinese Companies, Reuters (Mar. 6, 2024), https://perma.cc/6LYE-64J6. 29 The U.S. government has recognized that foreign government. propaganda is an industry-wide challenge for online platforms. See, e.g., Nat'l Intel. Council, Declassified Intelligence Community Assessment, Foreign Threats to the 2020 US Federal Elections (Mar. 10, 2021), https://perma.cc/VD3Y-VXSB. YouTube, for example, added disclaimers to certain channels that were reportedly being used to spread disinformation on behalf of the Russian government. Paresh Dave & Christopher Bing, Russian Disinformation on YouTube Draws Ads, Lacks Warning Labels - Researchers, Reuters (June 7, 2019), https://perma.cc/2BEJ-VKGW. Like others in the industry, TikTok publishes transparency reports on attempts by users to use the platform for government propaganda purposes. See TikTok, Countering Influence Operations (last visited May 6, 2024), https://perma.cc/AB39-S8FJ. 53 (Page 54 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 55 of 70 88. The Act is also over-inclusive because it applies to other Byte Dance Ltd.-owned applications that Congress has not shown and could not possibly prove pose the risks the Act apparently seeks to address. - 89. At a minimum, the Act fails intermediate scrutiny. Even if strict scrutiny did not apply, the Act would still fail intermediate scrutiny as a time, place, and manner restriction: the Act prohibits speech activity on TikTok at all times, in all places, and in all manners anywhere across the United States. To pass intermediate scrutiny, a law must be "narrowly tailored to serve a significant governmental interest.” McCullen v. Coakley, 573 U.S. 464, 486 (2014). This means that it must not "burden substantially more speech than is necessary to further the government's legitimate interests," Turner, 512 U.S. at 661-62, and "leave open ample alternative channels for communication of the information," Clark v. Cmty. for Creative Non-Violence, 468 U.S. 288, 293 (1984). 90. For many of the same reasons the Act cannot satisfy strict scrutiny, it also cannot satisfy intermediate scrutiny: (Page 55 of Total) 54

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 56 of 70 91. As discussed supra ¶¶67-69, the government has failed to establish that its apparent data security and propaganda concerns with Tik Tok are non-speculative. And as discussed supra ¶¶ 73-81, the Act. burdens substantially more speech than necessary because there are many less restrictive alternatives Congress could have adopted to address any legitimate concerns. The Act also fails intermediate scrutiny because it “effectively prevents” TikTok Inc. “from reaching [its] intended audience" and thus "fails to leave open ample alternative means of communication." Edwards v. City of Coeur d'Alene, 262 F.3d 856, 866 (9th Cir. 2001). 92. Regardless of the level of scrutiny, the Act violates the First Amendment for two additional reasons. 93. The Act forecloses an entire medium of expression. First, by banning TikTok in the United States, the Act "foreclose[s] an entire medium of expression." City of Ladue v. Gilleo, 512 U.S. 43, 56 (1994). A "long line of Supreme Court cases indicates that such laws are almost never reasonable." Anderson v. City of Hermosa Beach, 621 F.3d 1051, 1064-65 (9th Cir. 2010). (Page 56 of Total) 55

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 57 of 70 94. The Act is constitutionally overbroad. Second, the Act is facially overbroad. A law is "overbroad if a substantial number of its. applications are unconstitutional, judged in relation to the statute's plainly legitimate sweep." United States v. Stevens, 559 U.S. 460, 473 (2010) (citation omitted). Here, for example, the government has never contended that all or even most of the content on TikTok (or any other Byte Dance-owned application) represents misinformation, or propaganda. Yet the Act shuts down all speech on ByteDance-owned applications at all times, in all places, and in all manners. That is textbook overbreadth. See, e.g., Bd. of Airport Comm'rs v. Jews for Jesus, Inc., 482 U.S. 569, 574–75 (1987). disinformation, Ground 2: Unconstitutional Bill of Attainder 95. The Act is an unconstitutional bill of attainder. Article I of the U.S. Constitution prohibits Congress from passing any bill of attainder. U.S. Const. art. I § 9, cl. 3 ("No Bill of Attainder or ex post facto Law shall be passed."). A bill of attainder is "legislative punishment, of any form or severity, of specifically designated persons or groups." United States v. Brown, 381 U.S. 437, 447 (1965). The protection against bills of attainder is “an implementation of 56 (Page 57 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 58 of 70 the separation of powers, a general safeguard against legislative exercise of the judicial function, or more simply trial by legislature." Id. at 442. - 97. By singling out Petitioners for legislative punishment, the Act is an unconstitutional bill of attainder. 98. The Act inflicts "pains and penalties" that historically have been associated with bills of attainder. See Nixon v. Adm'r of Gen. Servs., 433 U.S. 425, 474 (1977). Historically, common "pains and penalties" included "punitive confiscation of property by the sovereign” and “a legislative enactment barring designated individuals or groups from participation in specified employments or vocations," among others. Id. As described above, the Act confiscates Petitioners' U.S. businesses by forcing ByteDance to shutter them within 270 days or sell on terms that are not commercially, technologically, or legally feasible. See supra ¶¶26-29. For the same reason, the Act bars Petitioners from operating in their chosen line of business. 99. "[V]iewed in terms of the type and severity of burdens imposed" on Petitioners, the Act's treatment of Petitioners cannot "reasonably ... be said to further nonpunitive legislative purposes." Nixon, 433 U.S. at 475–76. The Act transforms Petitioners into a “vilified 57 (Page 58 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 59 of 70 class" by explicitly prohibiting their current and future operations in the United States, without qualification or limitation, but does not extend the same treatment to other similarly situated companies. Foretich v. United States, 351 F.3d 1198, 1224 (D.C. Cir. 2003). 100. Moreover, in light of the less restrictive alternatives discussed above, there is no justification for automatically barring Petitioners' current and future operations in the United States (or those of its subsidiaries or successors) in perpetuity without providing them a meaningful opportunity to take corrective action. See Kaspersky Lab, Inc. v. U.S. Dep't of Homeland Sec., 909 F.3d 446, 456 (D.C. Cir. 2018). Indeed, the Act imposes this punishment uniquely on Petitioners without the process, and presidential determination of a significant national security threat, that Congress has afforded to everyone else. Expressly singling out Petitioners for these punitive burdens while at the same time adopting a statutory standard and decision-making process applicable to every other entity makes clear that Petitioners are subjected to a prohibited legislatively imposed punishment. 101. Moreover, while Petitioners can avoid the Act's prohibitions only via a wholesale divestment, all other companies 58 even those with (Page 59 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 60 of 70 Chinese ownership and determined by the President to present a "significant threat" to U.S. national security ― can avoid prohibition simply by operating a website or an application "whose primary purpose is to allow users to post product reviews, business reviews, or travel information and reviews." Sec. 2(g)(2)(b). 102. Indeed, any other "adversary-controlled" company that operates an application exactly like TikTok, but also operates a website the primary purpose of which is to post product reviews, is left untouched, leaving a ready path for any company but those affiliated with Petitioners to circumvent the Act's prohibitions altogether. For all practical purposes, then, the Act applies to just one corporate group is a "Tik Tok bill," as congressional leaders have described it.30 - it 103. For all of these reasons, the Act constitutes an unconstitutional bill of attainder. 30 Rachel Dobkin, Mike Johnson's Letter Sparks New Flood of Republican Backlash, Newsweek (Apr. 17, 2024), https://perma.cc/Z5HD-7UVU (quoting letter from Speaker Johnson referencing the “TikTok_bill”); Senator Chuck Schumer, Majority Leader, to Colleagues (Apr. 5, 2024), https://perma.cc/J7Q4-9PGJ (referencing “TikTok legislation”). 59 (Page 60 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 61 of 70 Ground 3: Violation of Equal Protection 104. The Act also violates Petitioners' rights under the equal protection component of the Fifth Amendment's Due Process Clause because it singles Petitioners out for adverse treatment without any reason for doing so. 105. First, the Act deems any application offered by Petitioners to be a “foreign adversary controlled application" without notice or a presidential determination. Sec. 2(g)(3)(A). By contrast, applications offered by other companies "controlled by a foreign adversary" are deemed to be "foreign adversary controlled applications" only after notice. and a presidential determination that those companies present "significant threat[s]" to U.S. national security, a determination that must be supported by evidence submitted to Congress. Sec. 2(g)(2)(B); see supra 34(d). 106. That distinction imposes a dramatically heavier burden on Petitioners' free speech rights without any justification. The Act precludes the government from burdening the speech rights of any speakers other than Petitioners unless and until the President issues a public report on the specific national security concerns animating the 60 (Page 61 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 62 of 70 President's decision, provides support for that decision, and describes the assets requiring divestiture. Those protections ensure that the President must, at the very least, provide a detailed national security justification for his or her actions before burdening other speakers' speech a justification that then will provide the basis for judicial review. The Act imposes none of those requirements as a precondition for burdening Petitioners' speech it levies that burden by unexplained legislative fiat. — 107. Second, the Act denies Petitioners the exemption available to any other company that is purportedly “controlled by a foreign adversary." As noted, any application Petitioners offer is ipso facto deemed a "foreign adversary controlled application." By contrast, other companies "controlled by a foreign adversary" are exempt from the Act's definition of a "covered company," and thus from the Act's requirements, so long as they offer at least one application with the "primary purpose" of “allow[ing] users to post product reviews, business reviews, or travel information and reviews." Sec. 2(g)(2)(B). 108. There is no conceivable reason for treating Petitioners differently than all other similarly situated companies. Even if Congress 61 (Page 62 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 63 of 70 had valid interests in protecting U.S. users' data and controlling what content may be disseminated through global platforms that would be advanced through the Act, there is no reason why those concerns would support a ban on Petitioners' platforms without corresponding bans on other platforms. Nor is there any rational reason why Congress would ban Petitioners' platforms while allowing any other company "controlled by a foreign adversary" - regardless of the national security threat posed by that company to sidestep the Act's reach by simply offering an - application that “allows users to post product reviews, business reviews, or travel information and reviews," but changing nothing else about the company's operations, ownership structure, or other applications. 109. By treating Petitioners differently from others similarly situated, the Act denies Petitioners the equal protection of the law. Ground 4: Unconstitutional Taking 110. The Act effects an unlawful taking of private property without just compensation, in violation of the Fifth Amendment's Takings Clause. 111. The Takings Clause provides that “private property” shall not be "taken for public use, without just compensation." U.S. Const. amend. V, cl. 5. The Act does just that by shutting down ByteDance's 62 (Page 63 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 64 of 70 U.S. businesses or, to the extent any qualified divestiture alternative is even feasible (it is not), compelling ByteDance to sell those businesses. under fire-sale circumstances that guarantee inadequate compensation. 112. Petitioners have substantial property interests in, and associated with, their and their affiliates' U.S. operations. These include not only ByteDance Ltd.'s interest in TikTok Inc. and other U.S. businesses, but also the platforms and applications themselves. See Kimball Laundry Co. v. United States, 338 U.S. 1, 11–13 (1949) (Takings Clause also protects losses to going-concern value of business). 113. If the Act's prohibitions take effect, they will deprive Petitioners of property protected by the Takings Clause. Absent a qualified divestiture, the Act will shutter Petitioners' businesses in the United States. And even if a qualified divestiture were feasible (it is not), any sale could be, at best, completed only at an enormous discount to the U.S. businesses' current market value, given the forced sale conditions. See BFP v. Resol. Tr. Corp., 511 U.S. 531, 537 (1994) (“[M]arket value, as it is commonly understood, has no applicability in the forced-sale context; indeed, it is the very antithesis of forced-sale value."). (Page 64 of Total) 63

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 65 of 70 114. Because the Act compels ByteDance "to relinquish specific, identifiable property" or forfeit "all economically beneficial uses," the Act effects a per se taking. Horne v. Dep't of Agric., 576 U.S. 350, 364-65 (2015); Lucas v. S.C. Coastal Council, 505 U.S. 1003, 1019 (1992). 115. Alternatively, the Act inflicts a regulatory taking. Even when a law does not compel the physical invasion of property or deprive the property of all economically viable use, it still effects a taking "if [it] goes too far." Penn. Coal Co. v. Mahon, 260 U.S. 393, 415 (1922). In determining when a law "goes too far," courts have typically looked to "several factors" identified in Penn Central Transportation Co. v. City of New York, 438 U.S. 104, 124 (1978), namely, (a) “[t]he economic impact of the regulation”; (b) “the extent to which the regulation has interfered with reasonable investment-backed expectations"; and (c) "the character of the governmental action." The Act inflicts a regulatory taking under each of these three factors. 116. The Act does not compensate Petitioners (let alone provide just compensation) for the dispossession of their U.S. businesses. See United States v. Miller, 317 U.S. 369, 373 (1943). Prospective injunctive (Page 65 of Total) 64

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 66 of 70 relief is accordingly warranted. See, e.g., Youngstown Sheet & Tube Co. v. Sawyer, 343 U.S. 579, 585 (1952). Requested Relief relief: Petitioners respectfully request that this Court grant the following A. Issue a declaratory judgment that the Act violates the U.S. Constitution; B. Issue an order enjoining the Attorney General from enforcing the Act; C. Enter judgment in favor of Petitioners; and D. Grant any further relief that may be appropriate. (Page 66 of Total) 65

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 67 of 70 DATED: May 7, 2024 Andrew J. Pincus Avi M. Kupfer MAYER BROWN LLP 1999 K Street, NW Washington, DC 20006 Telephone: 202-263-3220 Email: [email protected] [email protected] Respectfully submitted, /s/ Alexander A. Berengaut Alexander A. Berengaut David M. Zionts Megan A. Crowley COVINGTON & BURLING LLP One CityCenter 850 Tenth Street, NW Washington, DC 20001 Telephone: (202) 662-6000 Email: [email protected] [email protected] [email protected] John E. Hall Anders Linderot COVINGTON & BURLING LLP The New York Times Building 620 Eighth Avenue New York, New York 10018 Telephone: (212) 841-1000 Email: [email protected] [email protected] Counsel for Petitioners (Page 67 of Total) 66

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 68 of 70 IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT TIKTOK INC., and BYTEDANCE LTD., V. ) Petitioners, No. 24-1113 MERRICK B. GARLAND, in his official capacity as Attorney General of the United States, Respondent. CORPORATE DISCLOSURE STATEMENT Petitioners state as follows: ByteDance Ltd. is a privately held corporation incorporated in the Cayman Islands. ByteDance Ltd. subsidiaries provide a suite of more than a dozen products and services that allow people to connect with, create, and consume content on the Internet. ByteDance Ltd. has no (Page 68 of Total) 1

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 69 of 70 parent company, and no publicly traded company owns 10% or more of Byte Dance Ltd.'s stock. Tik Tok Inc. is a California-incorporated company that provides the TikTok platform in the United States. TikTok Inc. is a wholly owned subsidiary of TikTok LLC, which is a wholly owned subsidiary of TikTok Ltd. TikTok Ltd. is a wholly owned subsidiary of ByteDance Ltd. TikTok Inc. has no other parent company, and no publicly held corporation owns 10% or more of its stock. (Page 69 of Total) 2 /s/Alexander A. Berengaut Alexander A. Berengaut Counsel for Petitioners

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 70 of 70 CERTIFICATE OF SERVICE I hereby certify that on this 7th day of May, I caused copies of the foregoing Petition for Review and Corporate Disclosure Statement to be served upon the following recipients. By certified mail, postage prepaid: Merrick B. Garland Attorney General of the United States U.S. Department of Justice 950 Pennsylvania Avenue, NW Washington, DC 20530 By hand delivery: Matthew M. Graves United States Attorney 601 D Street, NW Washington, DC 20579 /s/ Alexander A. Berengaut Alexander A. Berengaut Counsel for Petitioners (Page 70 of Total)

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 1 of 7 (Page 71 of Total) EXHIBIT A

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 2 of 7 (Page 72 of Total) H. R. 815-61 Fusion Development Strategy programs of the People's Republic of China, including the following: (1) A brief summary of each such identified field and its relevance to the military power and national security of the People's Republic of China. (2) The implications for the national security of the United States as a result of the leadership or dominance by the People's Republic of China in each such identified field and associated supply chains. (3) The identification of at least 10 entities domiciled in, controlled by, or directed by the People's Republic of China (including any subsidiaries of such entity), involved in each such identified field, and an assessment of, with respect to each such entity, the following: (A) Whether the entity has procured components from any known United States suppliers. (B) Whether any United States technology imported by the entity is controlled under United States regulations. (C) Whether United States capital is invested in the entity, either through known direct investment or passive investment flows. (D) Whether the entity has any connection to the Peo- ple's Liberation Army, the Military-Civil Fusion program of the People's Republic of China, or any other state-spon- sored initiatives of the People's Republic of China to sup- port the development of national champions. (c) APPROPRIATE CONGRESSIONAL COMMITTEES DEFINED.-In this section, the term "appropriate congressional committees" means- (1) the Committee on Foreign Affairs of the House of Rep- resentatives; (2) the Committee on Armed Services of the House of Representatives; (3) the Committee on Foreign Relations of the Senate; and (4) the Committee on Armed Services of the Senate. DIVISION H-PROTECTING AMERICANS FROM FOREIGN ADVERSARY CON- TROLLED APPLICATIONS ACT SEC. 1. SHORT TITLE. This division may be cited as the "Protecting Americans from Foreign Adversary Controlled Applications Act”. SEC. 2. PROHIBITION OF FOREIGN APPLICATIONS. ADVERSARY CONTROLLED (a) IN GENERAL.— (1) PROHIBITION OF FOREIGN ADVERSARY CONTROLLED APPLICATIONS.-It shall be unlawful for an entity to distribute, maintain, or update (or enable the distribution, maintenance, or updating of) a foreign adversary controlled application by carrying out, within the land or maritime borders of the United States, any of the following:

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 3 of 7 (Page 73 of Total) H. R. 815-62 (A) Providing services to distribute, maintain, or update such foreign adversary controlled application (including any source code of such application) by means of a marketplace (including an online mobile application store) through which users within the land or maritime borders of the United States may access, maintain, or update such application. (B) Providing internet hosting services to enable the distribution, maintenance, or updating of such foreign adversary controlled application for users within the land or maritime borders of the United States. (2) APPLICABILITY.-Subject to paragraph (3), this sub- section shall apply― (A) in the case of an application that satisfies the definition of a foreign adversary controlled application pursuant to subsection (g)(3)(A), beginning on the date that is 270 days after the date of the enactment of this division; and (B) in the case of an application that satisfies the definition of a foreign adversary controlled application pursuant to subsection (g)(3)(B), beginning on the date that is 270 days after the date of the relevant determination of the President under such subsection. (3) EXTENSION. With respect to a foreign adversary con- trolled application, the President may grant a 1-time extension of not more than 90 days with respect to the date on which this subsection would otherwise apply to such application pursuant to paragraph (2), if the President certifies to Congress that- (A) a path to executing a qualified divestiture has been identified with respect to such application; (B) evidence of significant progress toward executing such qualified divestiture has been produced with respect to such application; and (C) there are in place the relevant binding legal agree- ments to enable execution of such qualified divestiture during the period of such extension. (b) DATA AND INFORMATION PORTABILITY TO ALTERNATIVE APPLICATIONS.-Before the date on which a prohibition under sub- section (a) applies to a foreign adversary controlled application, the entity that owns or controls such application shall provide, upon request by a user of such application within the land or maritime borders of United States, to such user all the available data related to the account of such user with respect to such application. Such data shall be provided in a machine readable format and shall include any data maintained by such application with respect to the account of such user, including content (including posts, photos, and videos) and all other account information. (c) EXEMPTIONS.— (1) EXEMPTIONS FOR QUALIFIED DIVESTITURES.-Subsection (a)— (A) does not apply to a foreign adversary controlled application with respect to which a qualified divestiture is executed before the date on which a prohibition under subsection (a) would begin to apply to such application; and

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 4 of 7 (Page 74 of Total) H. R. 815-63 (B) shall cease to apply in the case of a foreign adversary controlled application with respect to which a qualified divestiture is executed after the date on which a prohibition under subsection (a) applies to such applica- tion. (2) EXEMPTIONS FOR CERTAIN NECESSARY SERVICES.-Sub- sections (a) and (b) do not apply to services provided with respect to a foreign adversary controlled application that are necessary for an entity to attain compliance with such sub- sections. (d) ENFORCEMENT.— (1) CIVIL PENALTIES.― (A) FOREIGN ADVERSARY CONTROLLED APPLICATION VIO- LATIONS. An entity that violates subsection (a) shall be subject to pay a civil penalty in an amount not to exceed the amount that results from multiplying $5,000 by the number of users within the land or maritime borders of the United States determined to have accessed, maintained, or updated a foreign adversary controlled application as a result of such violation. (B) DATA AND INFORMATION VIOLATIONS.-An entity that violates subsection (b) shall be subject to pay a civil penalty in an amount not to exceed the amount that results from multiplying $500 by the number of users within the land or maritime borders of the United States affected by such violation. (2) ACTIONS BY ATTORNEY GENERAL.-The Attorney Gen- eral- (A) shall conduct investigations related to potential violations of subsection (a) or (b), and, if such an investiga- tion results in a determination that a violation has occurred, the Attorney General shall pursue enforcement under paragraph (1); and (B) may bring an action in an appropriate district court of the United States for appropriate relief, including civil penalties under paragraph (1) or declaratory and injunctive relief. (e) SEVERABILITY.― (1) IN GENERAL.-If any provision of this section or the application of this section to any person or circumstance is held invalid, the invalidity shall not affect the other provisions or applications of this section that can be given effect without the invalid provision or application. (2) SUBSEQUENT DETERMINATIONS.-If the application of any provision of this section is held invalid with respect to a foreign adversary controlled application that satisfies the definition of such term pursuant to subsection (g)(3)(A), such invalidity shall not affect or preclude the application of the same provision of this section to such foreign adversary con- trolled application by means of a subsequent determination pursuant to subsection (g)(3)(B). (f) RULE OF CONSTRUCTION.-Nothing in this division may be construed― (1) to authorize the Attorney General to pursue enforce- ment, under this section, other than enforcement of subsection (a) or (b);

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 5 of 7 (Page 75 of Total) H. R. 815-64 (2) to authorize the Attorney General to pursue enforce- ment, under this section, against an individual user of a foreign adversary controlled application; or (3) except as expressly provided herein, to alter or affect any other authority provided by or established under another provision of Federal law. (g) DEFINITIONS.-In this section: (1) CONTROLLED BY A FOREIGN ADVERSARY.-The term "con- trolled by a foreign adversary" means, with respect to a covered company or other entity, that such company or other entity is- (A) a foreign person that is domiciled in, is headquartered in, has its principal place of business in, or is organized under the laws of a foreign adversary country; (B) an entity with respect to which a foreign person or combination of foreign persons described in subpara- graph (A) directly or indirectly own at least a 20 percent stake; or (C) a person subject to the direction or control of a foreign person or entity described in subparagraph (A) or (B). (2) COVERED COMPANY.— (A) IN GENERAL.—The term "covered company" means an entity that operates, directly or indirectly (including through a parent company, subsidiary, or affiliate), a website, desktop application, mobile application, or aug- mented or immersive technology application that— (i) permits a user to create an account or profile to generate, share, and view text, images, videos, real- time communications, or similar content; (ii) has more than 1,000,000 monthly active users with respect to at least 2 of the 3 months preceding the date on which a relevant determination of the President is made pursuant to paragraph (3)(B); (iii) enables 1 or more users to generate or dis- tribute content that can be viewed by other users of the website, desktop application, mobile application, or augmented or immersive technology application; and (iv) enables 1 or more users to view content gen- erated by other users of the website, desktop applica- tion, mobile application, or augmented or immersive technology application. (B) EXCLUSION.—The term “covered company” does not include an entity that operates a website, desktop applica- tion, mobile application, or augmented or immersive tech- nology application whose primary purpose is to allow users to post product reviews, business reviews, or travel information and reviews. a (3) FOREIGN ADVERSARY CONTROLLED APPLICATION.―The term "foreign adversary controlled application" means website, desktop application, mobile application, or augmented or immersive technology application that is operated, directly or indirectly (including through a parent company, subsidiary, or affiliate), by— (A) any of (i) ByteDance, Ltd.;

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 6 of 7 (Page 76 of Total) (ii) TikTok; H. R. 815-65 (iii) a subsidiary of or a successor to an entity identified in clause (i) or (ii) that is controlled by a foreign adversary; or (iv) an entity owned or controlled, directly or indirectly, by an entity identified in clause (i), (ii), or (iii); or (B) a covered company that- (i) is controlled by a foreign adversary; and (ii) that is determined by the President to present a significant threat to the national security of the United States following the issuance of (I) a public notice proposing such determina- tion; and (II) a public report to Congress, submitted not less than 30 days before such determination, describing the specific national security concern involved and containing a classified annex and a description of what assets would need to be divested to execute a qualified divestiture. (4) FOREIGN ADVERSARY COUNTRY.-The term “foreign adversary country" means a country specified in section 4872(d)(2) of title 10, United States Code. (5) INTERNET HOSTING SERVICE.―The term "internet hosting service" means a service through which storage and computing resources are provided to an individual or organiza- tion for the accommodation and maintenance of 1 or more websites or online services, and which may include file hosting, domain name server hosting, cloud hosting, and virtual private server hosting. (6) QUALIFIED DIVESTITURE.—The term "qualified divesti- ture" means a divestiture or similar transaction that- (A) the President determines, through an interagency process, would result in the relevant foreign adversary controlled application no longer being controlled by a for- eign adversary; and (B) the President determines, through an interagency process, precludes the establishment or maintenance of any operational relationship between the United States operations of the relevant foreign adversary controlled application and any formerly affiliated entities that are controlled by a foreign adversary, including any cooperation with respect to the operation of a content recommendation algorithm or an agreement with respect to data sharing. (7) SOURCE CODE.-The term "source code" means the com- bination of text and other characters comprising the content, both viewable and nonviewable, of a software application, including any publishing language, programming language, pro- tocol, or functional content, as well as any successor languages or protocols. (8) UNITED STATES.-The term "United States" includes the territories of the United States. SEC. 3. JUDICIAL REVIEW. (a) RIGHT OF ACTION.-A petition for review challenging this division or any action, finding, or determination under this division

USCA Case #24-1113 Document #2053212 Filed: 05/07/2024 Page 7 of 7 (Page 77 of Total) H. R. 815-66 may be filed only in the United States Court of Appeals for the District of Columbia Circuit. (b) EXCLUSIVE JURISDICTION.-The United States Court of Appeals for the District of Columbia Circuit shall have exclusive jurisdiction over any challenge to this division or any action, finding, or determination under this division. (c) STATUTE OF LIMITATIONS.-A challenge may only be brought― (1) in the case of a challenge to this division, not later than 165 days after the date of the enactment of this division; and (2) in the case of a challenge to any action, finding, or determination under this division, not later than 90 days after the date of such action, finding, or determination. DIVISION I-PROTECTING AMERICANS' DATA FROM FOREIGN ADVERSARIES ACT OF 2024 SEC. 1. SHORT TITLE. This division may be cited as the "Protecting Americans' Data from Foreign Adversaries Act of 2024". SEC. 2. PROHIBITION ON TRANSFER OF PERSONALLY IDENTIFIABLE SENSITIVE DATA OF UNITED STATES INDIVIDUALS TO FOR- EIGN ADVERSARIES. (a) PROHIBITION.-It shall be unlawful for a data broker to sell, license, rent, trade, transfer, release, disclose, provide access to, or otherwise make available personally identifiable sensitive data of a United States individual to- (1) any foreign adversary country; or (2) any entity that is controlled by a foreign adversary. (b) ENFORCEMENT BY FEDERAL TRADE COMMISSION.― (1) UNFAIR OR DECEPTIVE ACTS OR PRACTICES.-A violation of this section shall be treated as a violation of a rule defining an unfair or a deceptive act or practice under section 18(a)(1)(B) of the Federal Trade Commission Act (15 U.S.C. 57a(a)(1)(B)). (2) POWERS OF COMMISSION.― (A) IN GENERAL.-The Commission shall enforce this section in the same manner, by the same means, and with the same jurisdiction, powers, and duties as though all applicable terms and provisions of the Federal Trade Commission Act (15 U.S.Č. 41 et seq.) were incorporated into and made a part of this section. (B) PRIVILEGES AND IMMUNITIES.-Any person who vio- lates this section shall be subject to the penalties and entitled to the privileges and immunities provided in the Federal Trade Commission Act. (3) AUTHORITY PRESERVED.-Nothing in this section may be construed to limit the authority of the Commission under any other provision of law. (c) DEFINITIONS.-In this section: (1) COMMISSION.-The term "Commission" means the Fed- eral Trade Commission.

November 2024 TOK Essay Prompts and Examples

Table of contents

• Writing Metier

I believe this is the time to share with you a list of November 2024 TOK essay prompts with descriptions that will be covered a little bit later. Yes, I will also give a guideline for each Nov 24 TOK title in the next part of this article.

Now, it’s show time! Let’s reveal these TOK topics for November 24.

List of November 2024 TOK prompts

• Does our responsibility to acquire knowledge vary according to the area of knowledge? Discuss with reference to history and one other area of knowledge.
• In the production of knowledge, is ingenuity always needed but never enough? Discuss with reference to mathematics and one other area of knowledge.
• How might it benefit an area of knowledge to sever ties with its past? Discuss with reference to two areas of knowledge.
• To what extent do you agree that there is no significant difference between hypothesis and speculation? Discuss with reference to the human sciences and one other area of knowledge.
• In the production of knowledge, are we too quick to dismiss anomalies? Discuss with reference to two areas of knowledge.
• In the pursuit of knowledge, what is gained by the artist adopting the lens of the scientist and the scientist adopting the lens of the artist? Discuss with reference to the arts and the natural sciences.

If you are expecting more information regarding each TOK November 2024 prompt, our expert IB TOK writers just shared their ideas with me, and am providing all the best AOKS , WOKS, RLSs that could be potentially used for each of these Theory of Knowledge essay titles.

If you want to get awesome sample TOK essays for several of the latest prompts, fill out our contact form with your sample requests, and I’ll try to get in touch with our IB experts and speed up the process with TOK 2024 November examples publishing. Maybe even share the samples with all of you, prior to publishing them online.

And now, let’s begin with detailed suggestions for each November TOK prompt.

1. Does our responsibility to acquire knowledge vary according to the area of knowledge?

The question is – Does our responsibility to acquire knowledge vary according to the area of knowledge? Discuss with reference to history and one other area of knowledge.

Alright, let’s break it down and get real about how we scoop up knowledge in different fields, like history versus the wild world of natural sciences. It’s like comparing apples and oranges, but each has its own cool vibe and unique challenges.

Area of Knowledge: History

Ways of Knowing:

• When we talk about Language and Memory in history, it’s all about piecing together past events like a detective solving a mystery. Stories from the past are passed down, and it’s on us to figure out what’s legit and what might be a little dressed up.
• Using Reason in history is like being a judge in a courtroom drama. You’ve got to weigh the evidence, check out different angles, and make a call on what really went down back in the day.

Real Life Situation:

• Picture the debates over the Treaty of Versailles. Different countries and historians have their own spins on it, depending on their own baggage and what they want to believe.

What’s the deal here?

• We’ve got to keep it real and consider all sides of the story, making sure we’re not just hearing what we want to.
• There’s this tricky thing called historical bias—when the past is tweaked to make someone’s present look better. Not cool, but it happens.

Area of Knowledge: Natural Sciences

• In natural sciences, Reason and Empiricism (like seeing is believing) are the big players. Scientists are always testing stuff out, trying to see what sticks.
• Sometimes, a scientist gets this hunch, an Intuition that guides them to new discoveries even before all the experiments are done.
• Think about climate change research. Scientists collect all this data, analyze it, and then drop the truth bombs on us, hoping to shape policies and save the planet.

What’s the scoop here?

• Accuracy is key. If you mess up the data, you could end up barking up the wrong tree, and that’s a disaster waiting to happen.
• Communicating what they find, especially the parts that aren’t so certain, is a big responsibility because it affects how everyone from policymakers to the average Joe reacts.

So, what’s the verdict?

Both historians and scientists are on a quest for truth, but the paths they take are lined with different types of mines. Historians need to juggle perspectives and keep biases at bay, while scientists have to be super careful with their methods and how they share their findings. In both cases, it’s all about getting to the heart of the matter without losing sight of the ethical side of things.

2. In the production of knowledge, is ingenuity always needed but never enough?

The question is – In the production of knowledge, is ingenuity always needed but never enough? Discuss with reference to mathematics and one other area of knowledge.

So, let’s get into it: when whipping up fresh knowledge, do we always gotta bring a dash of creativity to the table? Absolutely. But is that alone gonna cut it? Not really. We’ll break it down with some math and throw in a splash from the arts to spice things up.

Area of Knowledge: Mathematics

• Intuition plays a cool role in math. Ever have that ‘aha’ moment when a formula just clicks? That’s your brain doing a backflip of joy because it pieced the puzzle together before you even knew you were close.
• Logic is the bread and butter of math. It’s like the backbone, keeping everything straight and making sure all those wild ideas actually stack up.
• Think about the birth of calculus. Newton (and Leibniz, can’t forget him) needed some serious innovation to figure out problems of motion and change. But just dreaming up calculus wasn’t enough; they had to prove it worked through rigorous logic.
• Creativity in math? It’s all about seeing connections where no one else does. But without solid proof and logic to back it up, those ideas won’t fly.

Another Area of Knowledge: The Arts

• Emotion and Perception are big players here. Art isn’t just about splashing paint; it’s about conveying feelings and making people see things in a new light.
• Imagination is your best friend in the arts. It’s what pushes boundaries and creates something out of nothing.
• Consider Picasso’s “Guernica.” The ingenuity of his style brought the horrors of war into stark relief in a way that history books could never capture. Yet, without the context of the Spanish Civil War, its full impact might be missed.
• Sure, you need that spark of creativity to make art that stirs the soul. But it’s the deep understanding of human experiences and societal contexts that really makes that art resonate and stick with folks.

Whether you’re noodling through a math problem or painting a masterpiece, ingenuity is your starting line—it gets your brain engine revving. But it’s never the whole story. In math, you need the rigid framework of logic to bring those bright ideas to life. In the arts, it’s about connecting with hearts and minds through shared human experiences.

3. How might it benefit an area of knowledge to sever ties with its past?

The TOK title is – How might it benefit an area of knowledge to sever ties with its past? Discuss with reference to two areas of knowledge.

Let’s get this show on the road and talk about cutting the cord with the old school to make way for the new cool. Sounds risky, right? But sometimes, to kick things up a notch, you gotta let go of the past. Let’s see how this plays out in two different playgrounds: the ethical landscape of science and the ever-evolving world of art.

Area of Knowledge: Ethics in Science

• Reason and Ethics are the main dudes here. They keep scientists in check, making sure they’re not just chasing the next big breakthrough without considering the consequences.
• Intuition also has its moments, especially when deciding whether a new path is worth taking or too hot to handle.
• Think about the shift from using live animals in lab tests to advanced computer simulations. Dropping old methods that cause harm for cutting-edge tech that can do the job better and more humanely? That’s a win.
• Cutting ties with questionable past practices allows science to not only advance in technique but also grow in ethical stature. It’s like outgrowing old, dodgy habits that don’t fly in today’s world.
• Perception and Emotion rule the roost here. Art is all about how you see things and feel about them.
• Imagination goes wild in the arts, pushing boundaries and constantly reinventing the wheel.
• Consider the leap from classical forms like Renaissance art to radical movements like Abstract Expressionism. Artists like Pollock threw out the rule book on what painting was supposed to be and splashed their way to a whole new vibe.
• By ditching the strict, old-school techniques, artists open up a galaxy of new possibilities. It’s about breaking free from the mold and letting creativity run the show.

Both in the labs and on the canvases, there’s something to be said for letting go of the past. In science, moving past outdated practices not only boosts innovation but also ramps up the ethical game. In art, cutting ties with traditional forms lets creativity explode in new and unexpected ways.

4. To what extent do you agree that there is no significant difference between hypothesis and speculation?

The prompt here is – To what extent do you agree that there is no significant difference between hypothesis and speculation? Discuss with reference to the human sciences and one other area of knowledge.

Is there really a big difference between a hypothesis and just throwing out a wild guess? It might sound like we’re splitting hairs, but this gets real interesting when you look at how each plays out in the human sciences and, let’s say, the realm of mathematics.

Area of Knowledge: Human Sciences

• Reason and Empiricism take center stage here. Human sciences rely on these buddies to make sense of behaviors and social patterns.
• Intuition often kicks things off, suggesting a starting point for deeper exploration.
• Imagine a psychologist working on a new theory about why people binge-watch shows. They might start with a hunch (like, it’s about escaping stress), which is pretty speculative. But to move it into hypothesis territory, they need data and patterns that show it’s not just a one-off thing.
• A hypothesis in human sciences isn’t just any wild guess; it’s a guess grounded in some initial observations or theories. It’s about having a starting line that you can test and potentially prove right or wrong.

Another Area of Knowledge: Mathematics

• Logic is the name of the game in math. It’s all about clear, step-by-step reasoning where each stage locks into place.
• Intuition still gets a look in, especially when you’re first trying to figure out a problem.
• Let’s say a mathematician speculates that a certain complex equation could be solved in a simpler way. That’s their speculative shot in the dark. Turning that into a hypothesis involves setting up parameters and conditions under which this could be proven true or false.
• In math, the leap from speculation to hypothesis involves a tight framework where ideas must be rigorously tested against logical standards. You can’t just say, “I think so”; you need a “Here’s why, and here’s how we can prove it.”

While both hypotheses and speculations start as ideas, the key difference lies in the groundwork. In the human sciences, a hypothesis is like an educated guess ready for the trial by fire—testing it out through studies and experiments. In mathematics, it’s even more hardcore, with every hypothesis needing a strong backbone of logical proof to stand up.

5. In the production of knowledge, are we too quick to dismiss anomalies?

This TOK prompt is – In the production of knowledge, are we too quick to dismiss anomalies? Discuss with reference to two areas of knowledge.

When we’re cooking up new knowledge, do we sometimes kick anomalies to the curb too fast? It’s like, do we toss out the funky, unexpected bits just because they don’t fit the usual recipe? Let’s chew on this idea with a look at natural sciences and, for a twist, the world of economics.

• Empiricism (seeing is believing) usually rules here. Scientists rely on what they can observe and measure.
• Reason helps to make sense of those observations and figure out if something is a one-off or part of a bigger picture.
• Think about the discovery of penicillin. It was a total fluke, an anomaly in a petri dish that could’ve been tossed out with yesterday’s lab trash. But instead, it sparked a revolution in medicine.
• In science, anomalies are like hidden treasures that often get overlooked. But when they’re taken seriously, they can lead to breakthroughs that flip our understanding on its head.

Another Area of Knowledge: Economics

• Reason and Intuition play big roles here. Economists use them to predict trends and explain economic behaviors.
• Memory helps too, as understanding past economic patterns can offer insights into current anomalies.
• Let’s say a sudden, unexpected drop in unemployment occurs despite economic downturns. This anomaly might be brushed off as just a weird blip, but digging into it could uncover new insights about the resilience of certain industries or unexplored factors driving job creation.
• In economics, dismissing anomalies too quickly might mean missing out on understanding underlying mechanisms or new economic opportunities. It’s like ignoring pieces of a puzzle that don’t seem to fit at first glance.

Whether it’s in the lab or the stock market, we’re often too quick on the draw to dismiss the oddballs and outliers. But if history and breakthroughs have taught us anything, it’s that these anomalies can be gold mines of innovation and revelation. They challenge our standard recipes and push us to explore beyond the familiar boundaries.

6. In the pursuit of knowledge, what is gained by the artist adopting the lens of the scientist and the scientist adopting the lens of the artist?

The November 2024 title here is – In the pursuit of knowledge, what is gained by the artist adopting the lens of the scientist and the scientist adopting the lens of the artist? Discuss with reference to the arts and the natural sciences.

So here’s the skinny: what happens when artists start thinking like scientists, and scientists start getting all artsy? It sounds like a mad experiment, but stick with me—it’s actually a killer combo. Let’s peep what goes down when the arts and the natural sciences swap glasses and see the world through each other’s eyes.

Area of Knowledge: The Arts

• Perception and Emotion are the usual suspects driving the arts. It’s all about seeing the world and expressing those feels.
• Imagination takes you to places you’ve never dreamed of before.
• Imagine a painter who starts using scientific principles to choose their color palettes, based on color theory and the psychology behind hues. Or think about installations that incorporate elements of physics to create mind-bending optical illusions.
• By borrowing the scientific method, artists can explore new techniques and push the boundaries of what art can represent or make people feel. It’s like using a map to navigate uncharted territories, bringing precision to the wild, sprawling landscape of creativity.

Another Area of Knowledge: Natural Sciences

• Empiricism and Reason are the backbones here, with scientists relying heavily on data and the scientific method.
• Logic keeps everything on the straight and narrow.
• Think about a scientist studying bird migration but using an artistic approach to visualize the data, turning dry stats into a stunning visual map that tells a story. Or a chemist using abstract art concepts to explain molecular structures in a more intuitive and engaging way.
• By putting on the artist’s hat, scientists can communicate complex ideas in ways that resonate on a human level. This not only makes science more accessible but can also spark creativity in how experiments are designed or results are interpreted.

When artists get scientific and scientists get artistic, it’s like a brain-boosting crossfit workout. Artists gain a structured way to explore and present their work, tapping into the science of why things look or feel the way they do. Scientists, on the flip side, get a crash course in thinking outside the box—using creativity to enhance their discoveries and the way they share them with the world.

This cross-pollination can lead to breakthroughs that neither side might reach on their own. It’s all about blending the best of both worlds to explore new horizons and create something truly epic. So, whether you’re in a lab coat or a painter’s smock, throwing a bit of the other side’s style into your mix can crank your work up to eleven!

If you missed it, we also have a great selection of other TOK essay prompts with examples and sample papers, including May 2024 TOK titles .

The year 2023:

• November 2023 TOK essay prompts
• May 2023 TOK essay titles

The year 2022:

• November 2022 TOK essay prompts
• May 2022 ToK essay titles

Previous years’ prompts:

• November 2021 ToK Essay titles
• May 2021 Theory of Knowledge essay prompts

Each of November 2024 TOK prompts is a different piece of workout equipment, designed to stretch your intellectual muscles and pump up your critical thinking skills. Don’t just roll with the first thing that pops into your head. Test it, twist it, flip it upside down. Get creative, get wild, get weird.

Keep in your IB mind that these prompts are more than just homework—they’re your ticket to seeing the world in ways you never imagined. So, do not miss the submission deadline , grab that pen, hit the keyboard, and show those ideas who’s boss.

Let’s turn these thought experiments into epic brainstorms and maybe, just maybe, change the game of knowledge itself. And if you need a hand, you always know where to come first – Writing Metier !

Free topic suggestions

Vasy kafidoff.

Vasyl Kafidoff is a co-founder and CEO at WritingMetier. He is interested in education and how modern technology makes it more accessible. He wants to bring awareness about new learning possibilities as an educational specialist. When Vasy is not working, he’s found behind a drum kit.

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