SecProbe.io

October 21, 2011
 Via E-mail

Cameron Reynolds President and Chief Executive Officer VolitionRX Limited 150 Orchard Road Orchard Plaza 08-02 Singapore 238841
Re:  VolitionRX Limited
Form 8-K
Filed October 13, 2011
File No. 000-30402
Dear Mr. Reynolds:
We have reviewed your filing and have the following comment.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pleas e tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have additional comments.
General

1.  We reviewed your Form 8-K filed Octobe r 13, 2011 and determined  it does not include
the required information.  When a registrant c eases to be a shell company as the result of
a business acquisition, a Form 8-K that incl udes the information required by Items 2.01,
5.06 and 9.01 must be filed no later than four  business days after the consummation of
the acquisition transaction.  The 8-K must in clude the information, including financial
statements, that the acquired business would be  required to file to register a class of
securities under Section 12 of  the Exchange Act using Form 10.  We believe you were a
shell company (as defined by Rule 12b-2 of th e Exchange Act) immediately prior to the
acquisition of Singapore Volition Pte Limite d because you had nominal operations and
assets consisting of any amount of cash and cash equivalents and nominal other assets.
Accordingly, upon its initial filing, the Form 8-K should have included historical
financial statements of Singapore Voliti on Pte Limited and pro forma financial
information giving effect to the acquisition.  Please amend to provide this information.

Cameron Reynolds VolitionRX Limited October 21, 2011 Page 2

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exch ange Act rules require.  Since the company
and its management are in possession of all f acts relating to a company’s disclosure, they
are responsible for the accuracy and adequacy  of the disclosures they have made.
In responding to our comments, please provide a written statement from the
company acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;
• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.
Please contact Ronald E. Alper at (202) 551-3329 or David Link at (202) 551-3356 with
any other questions.
Sincerely,
/s/ David Link for
John Reynolds
Assistant Director

cc: Angela M. Fontanini, Esq.