The Chinese Room argument exploits a vague definition of instantiation that allows any series of events to be considered instantiations if only they're related to each other in the proper sequence.
However, this definition permits some very strange instantiations. For example, according to this definition, a sequence of program steps may be spread out over thousands of years and vast distances in space and still be in instantiation.
Such sequences aren't what is intended by computational instantiations. A better notion of instantiation would also require that a state be related to other states around it in a nonarbitary causal way.
Because this kind of nonarbitrariness is not exhibited in the Chinese Room, the Chinese Room is not an instantiation of a program.
Jerry Fodor, 1991.