China’s legal system is based on the civil law tradition and is heavily influenced by German law rather than English law, and so the concept of a “cause of action” as it exists in common law really isn’t applicable. Rather than having a well defined list of situations which are grounds for a law suit, civil law systems have a set of general principles involving rights and obligations.
Also the concept of a “tort” does not exist in civil law systems. Rather there is a concept of a “delict” which is a violation of a right that gives rise to an obligation. The whole concept of a “right” in the German law tradition is very, very different IMHO from the concept of a “right” in the Anglo-American legal tradition. (Basically in the Anglo-American tradition a right is something that the government cannot do, whereas in the German tradition “rights” are always paired with “obligations” and the entire system of civil ligitation is based on a series of right-obligation pairs.)
Having said that, because the laws are so new, and because much of the law has not been codified, Chinese judges play a much more important role in shaping the law than most of the counterparts in more developed civil law systems. A lot of what the law is is determined by judicial precedent, which gives Chinese law a different “feel” than most civil law systems.
I also don’t think that Chinese law will end up looking anything like American law, for the reason that every jurisdiction ends up with laws that look different from the laws of other jurisdictions. Even in cases where China borrows from the United States, the outcome might be quite different. The classic example is that China borrowed from US securities law the very strict separation between investment banking and commercial banking, and has kept this despite the fact that this separation has been abolished in the United States.