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October 4, 2023
Swee Guan Hoo
Chief Executive Officer
Energem Corp.
Level 3, Tower 11, Avenue 5, No. 8
Jalan Kerinchi, Bangsar South
Wilayah Persekutuan Kuala Lumpur, Malaysia
Re:Energem Corp.
Amendment No. 8 to Registration Statement on Form S-4
Filed September 26, 2023
File No. 333-268716
Dear Swee Guan Hoo:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our July 6, 2023, letter.
Amendment No. 8 to Form S-4
General
1.We note that your preliminary proxy statement filed on July 14, 2023, and definitive
proxy statement filed on July 24, 2023, make specific reference to November 18, 2023, as
the extended date for which shareholder approval was sought, and make no reference to
February 18, 2024. Accordingly, it appears that the shareholder meeting held on August
10, 2023, approved November 18, 2023 (and not February 18, 2024), as the new extension
deadline. Please revise disclosure throughout your Form S-4 to reflect November 18,
2023, as the extension deadline approved by the shareholder meeting held on August 10,
2023, or advise. Additionally ensure that your articles of association and the trust
agreement are amended for consistency.

 FirstName LastNameSwee Guan Hoo
 Comapany NameEnergem Corp.
 October 4, 2023 Page 2
 FirstName LastNameSwee Guan Hoo
Energem Corp.
October 4, 2023
Page 2
2.We note that the definition of "Public Units” on page six indicates that each public unit
consists of one public share and one-half of one public warrant. However, the Form S-1
filed in connection with your initial public offering discloses that each public unit consists
of one public share and one public warrant. Please revise or explain this apparent
inconsistency. In addition, we note that the ownership tables on pages 41, 43, and 78 (in
addition to the footnote to the table on page 174) include 4,152,778 public warrants,
which does not appear to correspond to the 11,500,000 units issued in your initial public
offering. Please revise or explain the difference in outstanding public warrants. In this
regard, we note that the warrant agreement filed as Exhibit 4.1 refers to 11,500,000
warrants, each exercisable for one share.
3.We note that the term "Private Placement Warrant(s)" is used, but does not appear to be
defined and, according to the tables on pages 41, 43, and 78 (and the footnote to the table
on page 174), represents 190,694 shares. By contrast, the term "Placement Warrants" is
defined on page 6, and appears to represent 528,075 shares. Please revise your disclosure
to reconcile these apparent inconsistencies or explain. In addition, revise your disclosure
to clearly describe how the private placement warrants will be treated in the business
combination. To the extent that private placement warrants will have provisions that differ
from public warrants following the business combination, revise the description of
warrants on page 128 to discuss these differences.
4.Please update information in your registration statement as of the most recent practicable
date. For instance, and without limitation, we note that the amount owing to the sponsor
under the promissory note is disclosed as of June 30, 2023.
Summary of the Proxy Statement/Prospectus, page 22
5.Please revise the diagram representing the post-business combination structure on page 23
to reflect the number of public shareholders following redemptions in connection with
your shareholder meeting on August 10, 2023. We note that the diagram discloses
3,593,769 shares held by the sponsor, directors, and officers, which does not appear to
correspond to the 3,403,075 Class A and Class B shares held by these parties according to
the table of beneficial ownership on page 122. Please revise or include appropriate
disclosure to reconcile this apparent inconsistency.
Summary Unaudited Pro Forma Condensed Combined Financial Information
Introduction, page 39
6.We note your disclosures on pages 39 and 168 that because Graphjet's fiscal year end is
different from Energem's fiscal year end, the financial information for the nine months
ended June 30, 2023 and the year ended September 30, 2022 was determined by adjusting
for the Energem's financial information for three months ended December 31, 2022 and
2021, respectively, which you state is included elsewhere in the filing but does not to
appear to be included as such. In order for investors to more easily reconcile the
disclosures in the pro forma Statement of Operations, please revise Note 2 to separately

 FirstName LastNameSwee Guan Hoo
 Comapany NameEnergem Corp.
 October 4, 2023 Page 3
 FirstName LastName
Swee Guan Hoo
Energem Corp.
October 4, 2023
Page 3
present the amounts from Energem's financial statements for the three months ended
December 31, 2021 and 2022 to reconcile to the amounts presented for the nine months
ended June 30, 2023 and the twelve months ended September 30, 2022 in each
of the pro forma Statement of Operations.
Risk Factors, page 42
7.Please revise to disclose that the PIPE may be terminated before the business combination
is completed and to discuss the related risks. In this regard, we note that the PIPE term
sheet has a termination date of October 31, 2023, and that the SEPA has already been
terminated.
Energem's listed securities may be subject to de-listing by Nasdaq, page 50
8.Please update to discuss whether you regained compliance with the Nasdaq minimum
value listing requirement by the September 27, 2023, deadline. Describe any
ongoing consequences and related risks to you and investors.
Proposal No. 2--The Business Combination Proposal
Background of the Business Combination, page 79
9.Your disclosure on page 80 that, "At this junction, EF Hutton has not performed
additional services and is not entitled to additional fees," appears inconsistent with
disclosure on page 169 that indicates EF Hutton will be paid a PIPE placement fee of 6%
($600,000) at closing. Please revise to reconcile and to disclose whether this fee is
contingent upon completion of the business combination.
Graphjet Technology SDN. BHD.
Financial Statements, page F-34
10.Please provide updated interim financial statements and related disclosures for Graphjet as
required by Rule 8-08 of Regulation S-X for the appropriate period of nine months ended
June 30, 2023. Please also ensure your reference to the periods covered by Graphjet’s
interim financial statements on pages 39, 168 and F-1 are consistent with the financial
statements included in the filing.
Exhibits
11.Please file updated exhibits to your registration statement. In this regard, we note the third
amended articles of association, amended trust agreement, amended share purchase
agreement, and lock-up agreement filed on Forms 8-K on August 16 and September 7,
2023. Additionally file any further amendments to your articles of association and the
trust agreement.

 FirstName LastNameSwee Guan Hoo
 Comapany NameEnergem Corp.
 October 4, 2023 Page 4
 FirstName LastName
Swee Guan Hoo
Energem Corp.
October 4, 2023
Page 4
            Please contact SiSi Cheng at 202-551-5004 or Melissa Gilmore at 202-551-3777 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jennifer Angelini at 202-551-3047 or Asia Timmons-Pierce at 202-551-3754 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Debbie Klis