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
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File numbers found in text: 333-220144
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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