Correspondence 0001104659-23-120999 from Zoomcar Holdings, Inc. (ZCAR, ZCARW) (CIK 0001854275) (ZCAR)
Zoomcar Holdings, Inc. (ZCAR, ZCARW) (CIK 0001854275)
Date: Nov. 24, 2023 · CIK: 0001854275 · Accession: 0001104659-23-120999
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File numbers found in text: 001-40964
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CORRESP
1
filename1.htm
November 24, 2023
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Trade & Services
100 F Street, NE
Washington, D.C. 20549
Attn: Jeff Gabor
Re:
Innovative International Acquisition Corp.
Preliminary Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934
Filed November 14, 2023
File No. 001-40964
Dear Mr. Gabor:
Innovative International Acquisition Corp., a
Cayman Islands exempted company (the “Company,” “we,” “our” or “us”), hereby transmits
the Company’s response to the comment received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission
(the “Commission”) during a telephone conversation on November 21, 2023, regarding the Company’s preliminary proxy statement
on Schedule 14A filed with the Commission on November 14, 2023.
In response to the Staff’s comment, the
Company confirms that on November 24, 2023, the Company instructed Equiniti Trust Company, LLC, as trustee with respect to the trust account
in which the proceeds of the initial public offering and simultaneous private placement were placed following the closing of the Company’s
initial public offering (the “Trust Account”), to hold funds in the Trust Account in an interest-bearing bank demand deposit
account, in order to mitigate the risk that the Company could be deemed to be operating as an unregistered investment company under the
Investment Company Act of 1940, as amended. The Company will revise and update the related disclosure in the definitive proxy statement.
We thank the Staff for its review of the foregoing
and the definitive proxy statement to be filed on November 24, 2023. If you have further comments, please feel free to contact to our
counsel, Sunyi Snow, at ssnow@mwe.com or by telephone at (214) 210-2810.
Sincerely,
Innovative International Acquisition
Corp.
By:
/s/
Mohan Ananda
Name: Mohan Ananda
Title: Chief Executive Officer, Innovative
International Acquisition Corp.