Enforcement problems plague shareholder activism and investor protection efforts in many parts of the world. These problems are particularly severe in transition economies, where weaknesses in legal and market constraints are prevalent. The importance of solving this problem has led legal scholars to consider a range of partial alternative solutions to domestic enforcement regimes. For example, Bernard Black and Reinier Kraakman devised a" self-enforcing" corporate law for Russia, designed specifically to minimize resort to legal authority.'John Coffee has recently emphasized the role of cross-listings on foreign stock exchanges as a mechanism by which firms in weak enforcement regimes can bond themselves to" good" corporate law-by listing on a foreign stock exchange that imposes high disclosure requirements and subjects listed firms to a stringent foreign regulatory and 2 private enforcement regime.

But there is another partial solution to the problem of weak investor protection and corporate law enforcement, one that has received no theoretical or empirical attention-the nonprofit organization (NPO). 3 This partial solution emerges from a puzzle at the center of contemporary East Asian corporate governance: nonprofit organizations have emerged as arguably the most important corporate law enforcement agents in Korea, Taiwan, and Japan. In Korea, the shareholders' rights committee of a large, diversified NPO known as People's Solidarity for Participatory Democracy (PSPD)" has brought the only significant shareholder actions to date,", 4 winning two major court victories, including one against the chairman and managers of a leading chaebol (a conglomerate dominated by a controlling minority shareholder). In Taiwan, a nonprofit foundation known as the Securities and Futures Institute (SFI), established with the support of the government and the financial sector, has organized and filed de facto class action suits in securities and corporate fraud cases on behalf of thousands of small investors. In Japan, a group of activist lawyers and academics calling themselves the Shareholder [Kabunushi] Ombudsman" dominates the market [for derivative actions], has