Correspondence 0001213900-22-080920 from Ace Global Business Acquisition Ltd (CIK 0001844389)
Ace Global Business Acquisition Ltd (CIK 0001844389)
Date: Dec. 19, 2022 · CIK: 0001844389 · Accession: 0001213900-22-080920
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2206-19 Jardine House 1
Connaught Road Central Hong
Kong SAR
Direct
Main
Fax
+852-3923-1111
+852-3923-1111
+852-3923-1100
December 19, 2022
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Attn: James Lopez, Taylor Beech, and Jennifer Lopez Molina
Re:
Ace Global Business Acquisition Limited
Amendment No. 1 to Preliminary Proxy Statement on Schedule 14A
Filed December 15, 2022
CIK No. 0001844389
Dear Mr. Lopez, Ms. Beech, and Ms. Molina:
On behalf of our client, Ace
Global Business Acquisition Limited (the “Company”), we submit to the staff of the Division of Corporation Finance
of the Commission (the “Staff”) this letter setting forth the Company’s response to the oral comment received
on December 19, 2022 (the “Oral Comment”) regarding the Company’s revised Preliminary Proxy Statement on Schedule
14A filed on December 15, 2022 (the “Amendment No. 1”). In response to the Oral Comment, the Company will add the following
risk factors to the end of the “Risks related to Potential Application of the Investment Company Act” section of the definitive
proxy statement:
If we are deemed to be an
investment company and subject to compliance with and regulation under the Investment Company Act, we would be subject to additional regulatory
burdens and expenses for which we have not allotted funds and for which we would not have sufficient time to comply with prior to the
expiration of its time to complete a business combination. As a result, if we were deemed to be an investment company, we would expect
to abandon its efforts to complete an initial business combination and instead to liquidate and dissolve. If we are required to liquidate
and dissolve, our investors would lose the opportunity to invest in a target company and would not be able to realize the benefits of
owning shares in the post-business combination company, including the potential appreciation of our share price following such a transaction.
In addition, in the event of our liquidation and dissolution, our warrants would expire worthless.
Please do not hesitate to
contact Lawrence Venick at (310) 728-5129 of Loeb & Loeb LLP with any questions or comments regarding this letter.
Sincerely,
/s/ Loeb & Loeb LLP
Loeb & Loeb LLP
cc: Eugene Wong