关键词: 公共数据；数据资产化；流通交易；数据产权；数据经纪商

Abstract: Promoting the assetization and value realization of public data is a key issue of concern for major global economies. Through qualitative research methods such as literature review and comparative analysis, this paper summarizes the rule construction and models of public data assetization in China, the United States, and the European Union. It concludes that China has established a system for the development and utilization of public data through authorized operation, the United States promotes the development and utilization of public data through open access and the cultivation of data brokers, while the European Union emphasizes the reuse of public data to accelerate its development and utilization. Through a comparative study in three aspects，such as property rights delineation, pricing formation, and circulation and trading, it is found that, compared with the U.S. and the EU, China’s pricing rules for public data assets are more operational. However, there is room for optimization in terms of property rights and circulation and trading. To accelerate the assetization of public data in China, it is advisable to continue encouraging judicial practices for data rights protection, promote legislation on data property rights, accelerate the construction of a national unified open platform for public data, and strengthen the cultivation of data brokers in China.

Key words: Public Data; Data Assetization; Circulation and Trading; Data Property Rights; Data Broker