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SEC Comment Letter for Agape ATP Corp (ATPC) (CIK 0001713210) (ATPC) — Oct 25, 2017

Agape ATP Corp (ATPC) (CIK 0001713210)
Date: Oct. 25, 2017 · CIK: 0001713210 · Accession: 0000000000-17-037691

AI Filing Summary & Sentiment

File numbers found in text: 333-220144

Date
October 24, 2017
Author
/s/ Brigitte Lippmann (for)
Form
UPLOAD
Company
Agape ATP Corp (ATPC) (CIK 0001713210)

Letter

Mail Stop 3561 October 24, 2017 Via E -mail How Kok Choong Chief Executive Officer Agape ATP Corporation No. 17, 17 -1, 17 -2, 17 -3, Wisma Laxton, Jalan Desa, Taman Desa, Off Jalan Klang Lama, 58100 Kuala Lumpur, Malaysia

Re: Agape ATP Corporation Amendment No. 1 to Registration Statement on Form S-1 Filed October 12 , 2017 File No. 333-220144

Dear Mr. How :

We have reviewed your amended registration statement 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 by amending your registration statement and providing the requested information. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your registration statement and the information you provide in respon se to these comments, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our September 20, 2017 letter.

Certain Relationships and Related Transactions, page 26

1. We note your response to comment 13. As previously requested, please state the names of your promoters and provide all information required by Item 404(c) of Regulation S - K.

You may contact James Giugliano at (202) 551 -3319 or Nasreen Mohammed at (202) 551-3773 if you have questions reg arding comments on the financial statements and related matters. Please contact Hillary Daniels at (202) 551 -3959 or Brigitte Lippmann at (202) 551 - 3713 with any other questions.

How Kok Choong Agape ATP Corporation October 24, 2017 Page 2

Sincerely,
/s/ Brigitte Lippmann (for)

Show Raw Text
Mail Stop 3561

October 24, 2017

Via E -mail
How Kok Choong
Chief Executive Officer
Agape ATP Corporation
No. 17, 17 -1, 17 -2, 17 -3, Wisma Laxton, Jalan Desa, Taman Desa,
Off Jalan Klang Lama, 58100 Kuala Lumpur, Malaysia

Re: Agape ATP Corporation
Amendment No. 1 to Registration Statement on Form S-1
Filed October 12 , 2017
  File No. 333-220144

Dear Mr. How :

We have reviewed your amended registration statement 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 by amending your registration statement and providing the
requested information.  If you  do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in respon se to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our September 20, 2017 letter.

Certain Relationships and Related Transactions, page 26

1. We note your response to comment 13.  As previously requested, please state the names
of your promoters and provide all information required by Item 404(c) of Regulation S -
K.

You may contact James Giugliano  at (202) 551 -3319 or Nasreen Mohammed  at (202)
551-3773 if you have questions reg arding comments on the financial statements and related
matters.  Please contact  Hillary Daniels  at (202) 551 -3959 or Brigitte Lippmann  at (202) 551 -
3713  with any other questions.

How Kok Choong
Agape ATP Corporation
October 24, 2017
Page 2

 Sincerely,

 /s/ Brigitte Lippmann (for)

 John Reynolds
 Assistant Director
Office of Beverages, Apparel, and
Mining

cc:  Jeffrey DeNunzio, President
       V Financial Group, LLC