SEC Comment Letter for Viewbix Inc. (VBIX) (CIK 0000797542) (QXL) — Jul 31, 2019
Viewbix Inc. (VBIX) (CIK 0000797542)
Date: July 31, 2019 · CIK: 0000797542 · Accession: 0000000000-19-011867
AI Filing Summary & Sentiment
Reasoning
Letter
July 31, 2019 Alon Dayan Chief Executive Officer Virtual Crypto Technologies, Inc. 11 Ha’amal Street Rosh Ha’ayin, Israel Re:Virtual Crypto Technologies, Inc. Form 8-K Filed July 25, 2019 Dear Mr. Dayan: 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 these comments 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 comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 8-K filed July 25, 2019 Item 2.01 Completion of Acquisition or Disposition of Assets, page 2 1.Based on your Form 10-Q for the fiscal quarter ended March 31, 2019, it appears that you were a shell company, as defined in Exchange Act Rule 12b-2, prior to the transactions described in the Form 8-K. In this regard, we note that, as of March 31, 2019, you had no assets other than cash and cash equivalents and no or nominal operations. Please provide us with your analysis of whether the transactions described in the Form 8-K resulted in a change in your shell company status. If they did, please amend the Form 8-K to include the disclosure required by Items 2.01(f) and 5.06 of Form 8-K, including the financial statements required by Item 9.01(a) and (b) of Form 8-K. 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. July 31, 2019 Page 2 FirstName LastName Alon Dayan Virtual Crypto Technologies, Inc. July 31, 2019 Page 2 You may contact Scott Anderegg, Staff Attorney at 202-551-3342 or Lilyanna Peyser, Special Counsel, at 202-551-3222 with any other questions. Sincerely, Division of Corporation Finance Office of Consumer Products
Show Raw Text
July 31, 2019
Alon Dayan
Chief Executive Officer
Virtual Crypto Technologies, Inc.
11 Ha’amal Street
Rosh Ha’ayin, Israel
Re:Virtual Crypto Technologies, Inc.
Form 8-K
Filed July 25, 2019
Dear Mr. Dayan:
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 these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 8-K filed July 25, 2019
Item 2.01 Completion of Acquisition or Disposition of Assets, page 2
1.Based on your Form 10-Q for the fiscal quarter ended March 31, 2019, it appears that you
were a shell company, as defined in Exchange Act Rule 12b-2, prior to the transactions
described in the Form 8-K. In this regard, we note that, as of March 31, 2019, you had no
assets other than cash and cash equivalents and no or nominal operations. Please provide
us with your analysis of whether the transactions described in the Form 8-K resulted in a
change in your shell company status. If they did, please amend the Form 8-K to include
the disclosure required by Items 2.01(f) and 5.06 of Form 8-K, including the financial
statements required by Item 9.01(a) and (b) of Form 8-K.
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.
July 31, 2019 Page 2
FirstName LastName
Alon Dayan
Virtual Crypto Technologies, Inc.
July 31, 2019
Page 2
You may contact Scott Anderegg, Staff Attorney at 202-551-3342 or Lilyanna Peyser,
Special Counsel, at 202-551-3222 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Consumer Products