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SEC Company Response from Scilex Holding (SCLX) — May 20, 2026

Scilex Holding Co
Date: May 20, 2026 · CIK: 0001820190 · Accession: 0001193125-26-232858

Offering / Registration Process

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Confidence
SEC Posture
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Reasoning

File numbers found in text: 333-295109

Date
May 20, 2026
Author
By
Form
CORRESP
Company
Scilex Holding Co

Letter

Scilex Holding Company 960 San Antonio Road Palo Alto, CA 94303 May 20, 2026 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Life Sciences Attention: Daniel Crawford 100 F Street, N.E. Washington, D.C. 20549-0406 Re: Scilex Holding Company Registration Statement on Form S-3, filed on April 16, 2026 File No. 333-295109 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-3 (File No. 333-295109) of the Company, filed with the Securities and Exchange Commission on April 16, 2026 (the “ Registration Statement ”), be accelerated so that the Registration Statement shall become effective at 4:00 p.m. (Eastern Time) on May 22, 2026, 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

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CORRESP
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 CORRESP

   Scilex Holding Company 960 San Antonio Road Palo Alto, CA 94303
 May 20, 2026 VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Life Sciences Attention: Daniel Crawford 100 F Street, N.E. Washington, D.C. 20549-0406   Re: Scilex Holding Company Registration Statement on Form S-3, filed on April 16, 2026 File No. 333-295109 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-3 (File No. 333-295109) of the Company, filed with the Securities and Exchange Commission on April 16, 2026 (the “ Registration Statement ”), be accelerated so that the Registration Statement shall become effective at 4:00 p.m. (Eastern Time) on May 22, 2026, 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

 President and Chief Executive Officer

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