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SEC Company Response from Scilex Holding (SCLX) — Dec 23, 2025

Scilex Holding Co
Date: Dec. 23, 2025 · CIK: 0001820190 · Accession: 0001193125-25-330492

Offering / Registration Process

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Reasoning

File numbers found in text: 333-292157

Date
December 23, 2025
Author
By
Form
CORRESP
Company
Scilex Holding Co

Letter

Re: Scilex Holding Company Registration Statement on Form S-1, filed on December 16, 2025 File No. 333-292157 Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Scilex Holding Company (the “ Company ”) hereby respectfully requests that the effectiveness of the Registration Statement on Form S-1 (File No. 333-292157) of the Company, filed with the Securities and Exchange Commission on December 16, 2025 (the “ Registration Statement ”) be accelerated so that the Registration Statement shall become effective at 4:00 p.m. (Eastern Time) on December 29, 2025, or as soon as possible thereafter. The Company hereby confirms that it is aware of its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed offering of the securities specified in the Registration Statement. It would be appreciated if, promptly after the Registration Statement has become effective, you would so inform our outside counsel, Jeffrey T. Hartlin of Paul Hastings LLP, by telephone at (650) 320-1804 or by email at jeffhartlin@paulhastings.com, and Elizabeth A. Razzano of Paul Hastings LLP, by telephone at (650) 320-1895 or by email at elizabethrazzano@paulhastings.com. The Company hereby authorizes Mr. Hartlin or Ms. Razzano of Paul Hastings LLP to orally modify or withdraw this request for acceleration.

Scilex Holding Company 960 San Antonio Road Palo Alto, CA 94303 December 23, 2025 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Attention: Office of Life Sciences 100 F Street, N.E. Washington, D.C. 20549-0406

Sincerely,
SCILEX HOLDING COMPANY

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CORRESP
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 filename1.htm

 CORRESP

 Scilex Holding Company
 960 San Antonio Road Palo Alto, CA
94303 December 23, 2025 VIA EDGAR
 United States Securities and Exchange Commission Division of
Corporation Finance Attention: Office of Life Sciences 100
F Street, N.E. Washington, D.C. 20549-0406

 Re:
 Scilex Holding Company
 Registration Statement on Form S-1, filed on December 16, 2025
 File No. 333-292157
 Ladies and Gentlemen: Pursuant to Rule 461
under the Securities Act of 1933, as amended, Scilex Holding Company (the “ Company ”) hereby respectfully requests that the effectiveness of the Registration Statement on Form S-1
(File No. 333-292157) of the Company, filed with the Securities and Exchange Commission on December 16, 2025 (the “ Registration Statement ”) be accelerated so that the
Registration Statement shall become effective at 4:00 p.m. (Eastern Time) on December 29, 2025, or as soon as possible thereafter.
 The Company hereby confirms that it is aware of its responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange
Act of 1934, as amended, as they relate to the proposed offering of the securities specified in the Registration Statement. It would be
appreciated if, promptly after the Registration Statement has become effective, you would so inform our outside counsel, Jeffrey T. Hartlin of Paul Hastings LLP, by telephone at (650) 320-1804 or by email at
jeffhartlin@paulhastings.com, and Elizabeth A. Razzano of Paul Hastings LLP, by telephone at (650) 320-1895 or by email at elizabethrazzano@paulhastings.com. The Company hereby authorizes Mr. Hartlin or
Ms. Razzano of Paul Hastings LLP to orally modify or withdraw this request for acceleration.

 Sincerely,

 SCILEX HOLDING COMPANY

 By:

 /s/ Henry Ji

 Henry Ji

 Chief Executive Officer and President

 cc:
 Jeffrey T. Hartlin (Paul Hastings LLP)
 Elizabeth A. Razzano (Paul Hastings LLP)