Dumplings at Chinese restaurants are fried, not pan-fried

Most dumplings served at Chinese restaurants are deep-fried in oil.
Don't you think there aren't many places that serve proper pan-fried dumplings??
Even the ones they give as free service are fried.
They just call them pan-fried dumplings.
Pan-fried dumplings and deep-fried dumplings are two different things.