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November 23, 2011
 Via Email

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
  Form 8-K/A
  Filed November 1, 2011
Dear Mr. Reynolds:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 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, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 8-K, filed October 13, 2011

 General

 1. Please tell us and disclose the fiscal year end that will be adopted by the post merger
entity.
2. Please amend your Form 8-K to update your fi nancial statements of Volition Rx Limited
for the quarter ended September 30, 2011.  Also  note that the Form 10-K for Standard
Capital Corporation is due 90 days after y ear end (August 31, 2011) as the registrant
remains subject to Exchange Act Ru les requiring an annual report.

Cameron Reynolds VolitionRX Limited November 23, 2011 Page 2

3. Please note that Item 2.01(f) and 5.01(a)(8) of  Form 8-K require the provision of Form 10
information for Volition as it is the acquiri ng entity and the entity whose operations are
more relevant on a going forward basis.  In several places, such as under Financial
Information on page 25, Executive Compensation on page 35, and Certain Relationships and Related Party Transacti ons and Director Independen ce on page 36, it is unclear
whether you have presented information re sponsive to Items 303, 402(m)-(r), and 404(d)
for Volition for the relevant periods.  In this respect your attention is directed to comment
one from our letter dated October 21, 2011.  Please revise or advise, as appropriate.

4. Please provide a separate section addressing Section 5.06 of Form 8-K Change in Shell
Company Status.
 Forward Looking Statements

5. We note your references to Section 27A of the Securities Act and Section 21E of the
Exchange Act.    Be advised these sections e xpressly state that the safe harbor for forward
looking statements does not apply to statem ents made by companies that issue penny
stock.  Please either:

 delete any reference to the Private Securities Litigation Reform
Act; or
 make clear, each time you refer to the Litigation Reform Act, that the safe
harbor does not apply to your company.
 Item 1.01

6. Please address, in greater detail, the material  terms of the share exchange agreement and
the impact they may have on investors going forward.  Without limit, we note Section 2.3
Outstanding and Future Issuances of Warra nts of Volition, Section 5.2 Cancellation of
SNDC Shares, and Section 5.3 Reverse Stock Split of SNDC.
 Item 3.02

7. Please expand to provide the information request ed by Item 701(d) of Regulation S-K.  In
this regard you should specify the Securities Act section or rule under which you claim an
exemption and briefly summarize the fact s you relied upon to make the exemption
available.
 Item 5.01

8. Please provide the percentage of voting securi ties now beneficially  owned by the Volition
shareholders.  See Item 5.01(a)(3) of Form 8-K.

Cameron Reynolds VolitionRX Limited November 23, 2011 Page 3

 9. Please provide the information requested by Item 5.01(a)(6) of Form 8-K.
 Item 8.01

10. Please provide a brief corporate history of Singapore Volition.
 Description of our Business, page 4

11. Please revise the disclosure throughout your document to consisten tly characterize your
development stage and the status of your pr oposed products.  For example, on page five
you state your “range of products will cont inue to expand” and refer to “existing
products.”  However, on page four and elsewhere you state you are a “development
stage” company with no revenues.  Your  revised disclosure  should address:

  the status of tests under development, including milestones achieved and required to
be achieved prior to commercialization;
  the status of any required governmental approvals;
 the detailed results of any e fficacy studies conducted; and,
  the timeframe and estimated expenditures required to commercialize your tests.

12. Provide the basis for your belief on page four th at your “tests will be able to better detect
and characterize cancer and othe r disease states than existi ng methods” given that you are
a development stage company or remove such disclosure.  Similarly, provide the basis for other statements made in the business secti on, such as the statement on page eight that
you believe your tests will be adopted quickly in the healthcare market.

13. Please provide the basis for the statement on page seven that the company will bring its
suite of NuQ blood tests to the market at the end of 2011, given the governmental
approvals that relate to  your proposed products.

14. We note several pictures rela ting to your proposed products, such as the mock-up of a
typical kit on page seven.  Please remove these pictures or re vise to add language
immediately following these photos to clarify th e lack of a product to date and that there
is no guarantee one will be developed.

15. On page six and elsewhere you make statem ents concerning your proposed products and
the results achieved to date.  For example you state you have “develope d tests for some of
the major nucleosome varieties and [you] ha ve shown [you] can detect the nucleosome
patterns …” and “[t]o date, ever y blood sample taken from patie nts with cancer that [you]
have tested is clearly positive in both of the NuQ-X tests (100%).  All blood samples taken from healthy patients have tested clea rly negative in both tests (0%).  Please revise
to substantiate all statements addressing th e efficacy of your proposed products.  Where
such statements are based on the results of scientific studie s, please clarify:

Cameron Reynolds VolitionRX Limited November 23, 2011 Page 4

  the nature and results of the studies performed, includi ng the number of samples
involved and the confidence levels associated with the results;
 who was responsible for performing the studies;
 whether the studies have been publishe d in any peer reviewed journals

In addition, please provide us copi es of any studies summarized.

16. On page nine you state “[t]he potential tota l market size for NuQ self-tests is over a
billion dollars annually, based on 30 million test  sales worldwide per year.”  You also
indicate the potential market  for your HyperGenomics tests would be in the hundreds of
millions of dollars. Please provide the basis for these statements, given your development stage or remove these statements.

17. We note several promotional statements th roughout your document such as your page
nine statement that your “hypergenomic t echnology has the potential  to be as ground
breaking and revolutionary as [your] NuQ suite  of tests …” and your statement on page
11 that you “expect rapid growth  as [your] products become st andard …” Please revise to
remove this and similar statements or provide  us with the basis fo r your conclusion that
your products are “ground br eaking and revolutionary.”

18. Discuss the lower regulatory ba rriers to the research mark et mentioned on page 10 and
where you are in the regulatory process for the research market.

19. Please provide a more detailed discussion of your plan of operations on page 10.  Discuss
in greater detail each milestone, the anticipated  time frame, the estimated costs, and the
impact that lack of funding will have upon the time frame.

20. Your disclosure on page 11 under Intellect ual Property indica tes you have patents
pending relating to several of your proposed tests.  Please disclose  the dates of the
applications .

21. Discuss in greater detail the “certain standa rds” and “certain pro cedures” you must follow
to receive the CE Mark.  Discuss in greater detail the governmental approval process, as
required by Item 101(h)(4)(viii) of Regulation S-K.  In addition, discuss the estimated
costs associated with the regulatory appr oval in the EU and in the United States.

22. Please discuss the material terms of the license  agreements and the material terms of the
acquisition of the patent applic ation for the endometriosis te st in June 2011.  See Item
101(h)(4)(vii) of Regulation S-K.

23. We note the disclosure in the last risk factor on page 21 rega rding the handling of
hazardous materials and that you may be subject to environmental liability.  Please provide the disclosure required by It em 101(h)(4)(xi) of Regulation S-K.

Cameron Reynolds VolitionRX Limited November 23, 2011 Page 5

 24. Please clarify the material terms of the Soft Repayable Grant and loan referred to on page
15.

25. Please provide the disclosure requested by It em 101(h)(4)(x) and (xii) of Regulation S-K.

Risks Associated with our Business, page 20

26. We note your page 22 risk factor that you re ly on third parties to manufacture and supply
your products.  In an appropriate location, pl ease summarize the material terms of these
arrangements.  In addition, please file any material agreements.
 Security Ownership of Certain Benefi cial Owners and Management, page 28

27. Please provide the disclosure required by Item 403(b) of Re gulation S-K.  For instance,
we note that you have not provided the disclo sure for each director individually.  In
addition, please include Mr. Root saert in the table individually, since he is the beneficial
owner of the shares held by Concord International.  Las tly, the amount owned by officers
and directors as a group should be revised to  reflect the shares beneficially owned by
officers and directors, such as the shar es held through Conc ord International.

Directors and Executive Officers, page 29

28. It is unclear whether your ex ecutive officers were involved w ith Singapore Volition prior
to the share exchange agreement. If so, pleas e revise the disclosure in this section to
provide the information required by Item 401( e) of Regulation S-K for each executive
officer, and as applicable scientific executives.
 29. Please provide the business experience for Mr. Innes for the past five years.  The only
disclosure provided for that time period we re non-executive board positions.  Similarly,
provide more specific business experience for Mr. Alexander.

30. Please remove the financial information rega rding prior business experience, as such
information does not present the complete financial information about those companies or transactions.

Certain Relationships and Related Party Trans actions, and Director Independence, page 36

31. We note your disclosure that, on May 31, 2011 “officers, directors, and their family
members acquired 12%” of your stock.  Please na me the purchasers and disclose the price
per share paid as well as the number of shares purchased.

Cameron Reynolds VolitionRX Limited November 23, 2011 Page 6

 Market Price of and Dividends on the Regist rant’s Common Equity and Related Stockholder
Matters, page 37

32. Please provide the information requested by Item 201(a)(iii) of Regulation S-K.
 Description of the Registrant’s Securities, page 38

33. Please provide the disclosure requir ed by Item 202 of Regulation S-K.
 Changes in and Disagreements with Accountants  on Accounting and Financial Disclosure, page
38
 34. We note that Standard Capital Corporation and Singapore Volition PTE, Ltd. both
engaged different independent auditors prior to the merg er.  Please confirm who the
independent auditor will be going forwar d for the combined company.  A reverse
acquisition always involves a change in acc ountants unless the same accountant audited
the pre-merger financial statements of both the operating company and the registrant.
The independent accountant that  will no longer be associat ed with the registrant’s
financial statements is considered the pred ecessor accountant.  Pleas e revise your Form 8-
K to include the required  disclosures in Item 304 of Regulation S-K.

Exhibits

35. Exhibits 3.01(b), 10.01, 10.02, 10.03, 10.04, 10.05, 10.06, 10.07, 10.08, 10.09, 10.10,
10.11, 10.12, 10.13, and 10.14 are filed in an improper el ectronic format.  Please note that
while you may file electronic documents as an  image as an unofficial copy, you must still
file your exhibits with an acceptable format.  Refer to Rule 102(a) of Regulation S-T and Section 2.01 of Volume II of the E DGAR Filer Manual.  Please revise.

36. We note several of your exhibits, including 10.05  and 10.06 appear to be filed in French.
Please revise to file English translations , as required by Rule  12b-12(d)(2) of the
Exchange Act.

37. Please file the Letter of Appointment with Dr. Faulkes on July 13, 2011 as an exhibit.

38. We note that Exhibits 10.01, 10.04, and 10.12 ha ve redacted portions of the exhibit
without filing a confidential treatment request pursuant to Rule 24b-2.  Please either file
the exhibits in their entirety or file a confidential treatment request.

Cameron Reynolds VolitionRX Limited November 23, 2011 Page 7

 Form 8-K/A filed on November 1, 2011

 Exhibit 99.1

 39. Where a comment is proposed on the interim fi nancial statements and may also apply to
the annual statements please make the a ppropriate revisions, where applicable.
 Unaudited Consolidated Financial statements

 40. Please amend your Form 8-K to include the stat ements of changes in shareholders’ equity
for the interim period presented of Singapore Volition Pte. Ltd.
 Consolidated Statement of Cash Flows, page 4

 41. Please tell us how you present the ValiBio SA  acquisition in your statement of cash flows
and explain why the acquisition is  not one line item in the i nvesting activities  section of
this statement.  Tell us how you considered FASB ASC 230-10-45-13.
42. You present on your statement of cash flows th at you issued shares to settle debt of
$318,244 during the six months ending June  30, 2011 and $753,404 from the date of
inception to June 30, 2011.  We further note you r related party loan balance decreased
from December 31, 2010 to June 30, 2011.  Tell us  if the shares issued to pay down debt
were issued to related parties in payment of you r debt to them.  If so, please disclose the
number of shares issued and the fair  value used to for settlement.
 Notes to Financial Statements, page 5

 2. Summary of Significant A ccounting Policies, page 5

 g) Foreign Currency Translation, page 6

 43. Please clarify whether your functional and re porting currency is the Euro or the U.S.
dollar.  In this paragraph you disclose that your functional cu rrency is the U.S. dollar but
on page seven under i) Comprehensive loss you di sclose recording the effects of foreign
currency translation from the Euro to the U.S. dollar.
 3. Acquisition of ValiBio SA, page 8

 44. We note the assets acquired in  the acquisition of ValiBio SA  in October 2010 represented
83% of Singapore Volition’s total assets at  December 31, 2010.  Please tell us how you
considered whether ValiBio SA should be  presented as a predecessor to Singapore
Volitions.  Please tell us how your presenta tion of ValiBio is appropriate and how you
determined that the historical financial info rmation of ValiBio should not be presented as
Singapore Volition’s predecessor.

Cameron Reynolds VolitionRX Limited November 23, 2011 Page 8

 45. Please tell us and disclose the reasons for the changes in the amount owed to ValiRX PLC
for your acquisition of ValiBio SA from $900,000 at December 321, 2010 to $1,376,63