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SEC Comment Letter 0000000000-22-013727 to GLOBALINK INVESTMENT INC. (GLLI, GLLIR, GLLIU, GLLIW) (CIK 0001888734)

GLOBALINK INVESTMENT INC. (GLLI, GLLIR, GLLIU, GLLIW) (CIK 0001888734)
Date: Dec. 20, 2022 · CIK: 0001888734 · Accession: 0000000000-22-013727

Regulatory Compliance Financial Reporting Risk Disclosure

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File numbers found in text: 001-4112

Date
December 20, 2022
Author
Cliff (Ming Hang) Chong
Form
UPLOAD
Company
GLOBALINK INVESTMENT INC. (GLLI, GLLIR, GLLIU, GLLIW) (CIK 0001888734)

Letter

United States securities and exchange commission logo December 20, 2022 Cliff (Ming Hang) Chong Chief Financial Officer Globalink Investment Inc. 1180 Avenue of the Americas, 8th Floor New York, NY 10036 Re:Globalink Investment Inc. Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31, 2021 Filed December 5, 2022 File No. 001-4112 Dear Cliff (Ming Hang) Chong: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31, 2021 General 1.With a view toward disclosure, please tell us whether your sponsor is, is controlled by, or has substantial ties with a non-U.S. person. If so, please revise your disclosure in future filings to include disclosure that addresses how this fact could impact your ability to complete your initial business combination. For instance, discuss the risk to investors that you may not be able to complete an initial business combination with a U.S. target company should the transaction be subject to review by a U.S. government entity, such as the Committee on Foreign Investment in the United States (CFIUS), or ultimately prohibited. Disclose that as a result, the pool of potential targets with which you could complete an initial business combination may be limited. Further, disclose that the time necessary for government review of the transaction or a decision to prohibit the transaction could prevent you from completing an initial business combination and require you to liquidate. Disclose the consequences of liquidation to investors, such as the losses

FirstName LastNameCliff (Ming Hang) Chong Comapany NameGlobalink Investment Inc. December 20, 2022 Page 2 FirstName LastName Cliff (Ming Hang) Chong Globalink Investment Inc. December 20, 2022 Page 2 of the investment opportunity in a target company, any price appreciation in the combined company, and the warrants, which would expire worthless. Please include an example of your intended disclosure in your response. 2.We note that you filed amended Forms 10-K and 10-Q for the periods ended December 31, 2021, March 30, 2022 and June 30, 2022 to restate your previously issued financial statements. Please also file an Item 4.02 8-K indicating that your previously issued financial statements, and related audit report, should no longer be relied upon. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or Robert Telewicz, Accounting Branch Chief at (202) 551-3438 if you have any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction

Show Raw Text
United States securities and exchange commission logo
December 20, 2022
Cliff (Ming Hang) Chong
Chief Financial Officer
Globalink Investment Inc.
1180 Avenue of the Americas, 8th Floor
New York, NY 10036
Re:Globalink Investment Inc.
Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31, 2021
Filed December 5, 2022
File No. 001-4112
Dear Cliff (Ming Hang) Chong:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Amendment No. 1 to Form 10-K for the Fiscal Year Ended December 31, 2021
General
1.With a view toward disclosure, please tell us whether your sponsor is, is controlled by, or
has substantial ties with a non-U.S. person.  If so, please revise your disclosure in future
filings to include disclosure that addresses how this fact could impact your ability to
complete your initial business combination.  For instance, discuss the risk to investors that
you may not be able to complete an initial business combination with a U.S. target
company should the transaction be subject to review by a U.S. government entity, such as
the Committee on Foreign Investment in the United States (CFIUS), or ultimately
prohibited.  Disclose that as a result, the pool of potential targets with which you could
complete an initial business combination may be limited.  Further, disclose that the time
necessary for government review of the transaction or a decision to prohibit the
transaction could prevent you from completing an initial business combination and require
you to liquidate.  Disclose the consequences of liquidation to investors, such as the losses

 FirstName LastNameCliff (Ming Hang) Chong
 Comapany NameGlobalink Investment Inc.
 December 20, 2022 Page 2
 FirstName LastName
Cliff (Ming Hang) Chong
Globalink Investment Inc.
December 20, 2022
Page 2
of the investment opportunity in a target company, any price appreciation in the combined
company, and the warrants, which would expire worthless.  Please include an example of
your intended disclosure in your response.
2.We note that you filed amended Forms 10-K and 10-Q for the periods ended December
31, 2021, March 30, 2022 and June 30, 2022 to restate your previously issued financial
statements.  Please also file an Item 4.02 8-K indicating that your previously issued
financial statements, and related audit report, should no longer be relied upon.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or Robert Telewicz,
Accounting Branch Chief at (202) 551-3438 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction