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May 7, 2020
Kenneth Ng
Chief Executive Officer
Malacca Straits Acquisition Co Ltd
Unit 601-2
St. George's Building
2 Ice House Street
Central Hong Kong
Re:Malacca Straits Acquisition Co Ltd
Draft Registration Statement on Form S-1
Submitted April 10, 2020
CIK No. 1807594
Dear Mr. Ng:
            We have reviewed your draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1 Submitted April 10, 2020
General
1.We note your disclosure that holders of your Class B ordinary shares will have the right to
elect all of your directors prior to your initial business combination. Please disclose
whether the company will be a controlled company as defined under Nasdaq's rules and
discuss the corporate governance exemptions that Nasdaq provides to a controlled
company. If applicable, include risk factor disclosure.

 FirstName LastNameKenneth Ng
 Comapany NameMalacca Straits Acquisition Co Ltd
 May 7, 2020 Page 2
 FirstName LastName
Kenneth Ng
Malacca Straits Acquisition Co Ltd
May 7, 2020
Page 2
Capitalization, page 67
2.Please revise the caption for “Class A ordinary shares, subject to redemption” to also
disclose par value and the number of shares outstanding.

3.It appears based on your disclosure on page 24 that redemption of the public shares is
independent of your liquidation and dissolution, which must be separately approved by
your remaining shareholders after such redemption. Please tell us why it is not appropriate
to classify these shares entirely as temporary equity pursuant to ASC 480-10-S99-3A. In
this regard, it appears that these securities are subject to a deemed liquidation event, not an
ordinary liquidation event as described in this guidance.
Note 5 - Commitments
Registration Rights, page F-13
4.Please disclose whether there are any maximum cash penalties under the registration
rights agreement, if applicable. Please also disclose any additional penalties resulting from
delays in registering your common stock. Refer to ASC 825-20-50-1.

            You may contact SiSi Cheng, Staff Accountant, at (202) 551-5004 or Kevin Stertzel,
Staff Accountant, at (202) 551-3723 if you have questions regarding comments on the financial
statements and related matters.  Please contact Sergio Chinos, Staff Attorney, at (202) 551-
7844 or Asia Timmons-Pierce, Special Counsel, at (202) 551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Stuart Neuhauser