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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

AI Filing Summary & Sentiment

File numbers found in text: 001-40964

Date
November 24, 2023
Author
Innovative International Acquisition
Form
CORRESP
Company
Zoomcar Holdings, Inc. (ZCAR, ZCARW) (CIK 0001854275)

Letter

Division of Corporation Finance Office of Trade & Services Preliminary Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934 Filed November 14, 2023 File No. 001-40964

Re: Innovative International Acquisition Corp.

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.

Show Raw Text
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.