SEC Comment Letter 0000000000-23-010488 to Value Exchange International, Inc. (VEII) (CIK 0001417664)
Value Exchange International, Inc. (VEII) (CIK 0001417664)
Date: Sept. 22, 2023 · CIK: 0001417664 · Accession: 0000000000-23-010488
AI Filing Summary & Sentiment
File numbers found in text: 000-53537
Letter
United States securities and exchange commission logo September 22, 2023 Channing Au Chief Financial Officer Value Exchange International, Inc. Unit 602, Block B, 6 Floor, Shatin Industrial Centre 5-7 Yuen Shun Circuit Shatin, N.T., Hong Kong SAR Re:Value Exchange International, Inc. Form 10-K for the Fiscal Year Ended December 31, 2022 File No. 000-53537 Dear Channing Au: We have reviewed your August 25, 2023 response to our comment letter 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. After reviewing your response to this comment, we may have additional comments. Form 10-K for Fiscal Year Ended December 31, 2022 General 1.We note your statement that you reviewed public filings and material contracts as well as your representation relating to the absence of foreign government representation on your board of directors in connection with your required submission under paragraph (a). Please supplementally describe any additional materials that were reviewed and explain your diligence with respect to your representation relating to the absence of foreign government representation on your board of directors. In addition, please tell us whether you relied upon any legal opinions or third party certifications such as affidavits as the basis for your submission.
FirstName LastNameChanning Au Comapany NameValue Exchange International, Inc. September 22, 2023 Page 2 FirstName LastName Channing Au Value Exchange International, Inc. September 22, 2023 Page 2 Please contact Jennifer Gowetski at 202-551-3401 or Jennifer Thompson at 202-551- 3737 with any questions. Sincerely, Division of Corporation Finance Disclosure Review Program cc: Paul Richter
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United States securities and exchange commission logo
September 22, 2023
Channing Au
Chief Financial Officer
Value Exchange International, Inc.
Unit 602, Block B, 6 Floor, Shatin Industrial Centre
5-7 Yuen Shun Circuit
Shatin, N.T., Hong Kong SAR
Re:Value Exchange International, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2022
File No. 000-53537
Dear Channing Au:
We have reviewed your August 25, 2023 response to our comment letter 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.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2022
General
1.We note your statement that you reviewed public filings and material contracts as well as
your representation relating to the absence of foreign government representation on your
board of directors in connection with your required submission under paragraph
(a). Please supplementally describe any additional materials that were reviewed and
explain your diligence with respect to your representation relating to the absence of
foreign government representation on your board of directors. In addition, please tell us
whether you relied upon any legal opinions or third party certifications such as affidavits
as the basis for your submission.
FirstName LastNameChanning Au
Comapany NameValue Exchange International, Inc.
September 22, 2023 Page 2
FirstName LastName
Channing Au
Value Exchange International, Inc.
September 22, 2023
Page 2
Please contact Jennifer Gowetski at 202-551-3401 or Jennifer Thompson at 202-551-
3737 with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc: Paul Richter