The empirical focus of this paper is the syntactic status of the semi-complementizer shuō grammaticalized from verbs of saying, in Mandarin Chinese. Such elements have been shown to exhibit atypical patterns compared to that in English, which triggers discussions of whether shuō should be analyzed as a complementizer (Paul, 2014; Huang, 2018). This paper presents novel data surrounding the distributional patterns of shuō and argues that shuō is a C head that introduces a subtype of CPs called non-referential CPs, following de Cuba (2017).