SEC Comment Letter for Viewbix Inc. (VBIX) (CIK 0000797542) (QXL) — Mar 21, 2019
Viewbix Inc. (VBIX) (CIK 0000797542)
Date: March 21, 2019 · CIK: 0000797542 · Accession: 0000000000-19-005438
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 000-15746
Letter
March 21, 2019 Alon Dayan Director and Chief Executive Officer Virtual Crypto Technologies, Inc. 11 Ha’amal Street Tel Aviv, Israel Re:Virtual Crypto Technologies, Inc. Preliminary Information Statement on Schedule 14C Filed February 26, 2019 File No. 000-15746 Dear Mr. Dayan: We have reviewed your filing and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Preliminary Information Statement on Schedule 14C filed February 26, 2019 General 1.We note your disclosure that the Reverse Stock Split is a condition to closing of the Share Exchange Agreement, which you have entered into to acquire 99.83% of Algomizer Ltd.'s holdings in Viewbix, Ltd. Because shareholders will not have a separate opportunity to vote upon your acquisition of the interest in Viewbix, Ltd., please revise your preliminary information statement to provide the disclosures required by Item 1 of Schedule 14C, which refers to Items 11, 13, and 14 of Schedule 14A, pursuant to Note A of Schedule 14A. Alternatively, provide us with a detailed legal analysis of why this information is not required. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
FirstName LastNameAlon Dayan Comapany NameVirtual Crypto Technologies, Inc. March 21, 2019 Page 2 FirstName LastName Alon Dayan Virtual Crypto Technologies, Inc. March 21, 2019 Page 2 Please contact Katherine Bagley, Staff Attorney, at (202) 551-2545 or Mara Ransom, Assistant Director, at (202) 551-3264 with any questions. Sincerely, Division of Corporation Finance Office of Consumer Products cc: Shachar Hadar
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March 21, 2019
Alon Dayan
Director and Chief Executive Officer
Virtual Crypto Technologies, Inc.
11 Ha’amal Street
Tel Aviv, Israel
Re:Virtual Crypto Technologies, Inc.
Preliminary Information Statement on
Schedule 14C
Filed February 26, 2019
File No. 000-15746
Dear Mr. Dayan:
We have reviewed your filing and have the following comment. In our comment, we
may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Preliminary Information Statement on Schedule 14C filed February 26, 2019
General
1.We note your disclosure that the Reverse Stock Split is a condition to closing of the Share
Exchange Agreement, which you have entered into to acquire 99.83% of Algomizer Ltd.'s
holdings in Viewbix, Ltd. Because shareholders will not have a separate opportunity to
vote upon your acquisition of the interest in Viewbix, Ltd., please revise your preliminary
information statement to provide the disclosures required by Item 1 of Schedule 14C,
which refers to Items 11, 13, and 14 of Schedule 14A, pursuant to Note A of Schedule
14A. Alternatively, provide us with a detailed legal analysis of why this information is
not required.
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
FirstName LastNameAlon Dayan
Comapany NameVirtual Crypto Technologies, Inc.
March 21, 2019 Page 2
FirstName LastName
Alon Dayan
Virtual Crypto Technologies, Inc.
March 21, 2019
Page 2
Please contact Katherine Bagley, Staff Attorney, at (202) 551-2545 or Mara Ransom,
Assistant Director, at (202) 551-3264 with any questions.
Sincerely,
Division of Corporation Finance
Office of Consumer Products
cc: Shachar Hadar