SEC Comment Letter 0000000000-22-012899 to ALPHATIME ACQUISITION CORP (ATMC, ATMCR, ATMCU, ATMCW) (CIK 0001889106)
ALPHATIME ACQUISITION CORP (ATMC, ATMCR, ATMCU, ATMCW) (CIK 0001889106)
Date: Nov. 30, 2022 · CIK: 0001889106 · Accession: 0000000000-22-012899
AI Filing Summary & Sentiment
Letter
United States securities and exchange commission logo November 29, 2022 Dajiang Guo Chief Executive Officer AlphaTime Acquisition Corp. 500 5th Avenue, Suite 938 New York, NY 10110 Re:AlphaTime Acquisition Corp. Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted November 2, 2022 CIK No. 0001889106 Dear Dajiang Guo: We have reviewed your amended draft registration statement 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 this letter by providing the requested information and either submitting an amended draft registration statement or publicly filing your registration statement on EDGAR. If you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing the information you provide in response to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. Amendment No. 1 to DRS Transfer of Cash to and from Our Post-Combination Organization If We Acquire a Company Based in China, page 10 1.We reissue comment 6 in part. Please describe any restrictions on the transfer of cash between entities within China after a business combination with a company based in China. Enforcement of Civil Liabilities, page 12 2.Please identify each officer and/or director located in China or Hong Kong and disclose that it will be more difficult to enforce liabilities and judgments on these individuals. Please also provide disclosure consistent with this section in the risk factor section. We
FirstName LastNameDajiang Guo Comapany NameAlphaTime Acquisition Corp. November 29, 2022 Page 2 FirstName LastName Dajiang Guo AlphaTime Acquisition Corp. November 29, 2022 Page 2 note the final risk factor on page 62. You may contact Todd Schiffman at 202-551-3491 or John Dana Brown at 202-551-3859 with any questions. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
November 29, 2022
Dajiang Guo
Chief Executive Officer
AlphaTime Acquisition Corp.
500 5th Avenue, Suite 938
New York, NY 10110
Re:AlphaTime Acquisition Corp.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted November 2, 2022
CIK No. 0001889106
Dear Dajiang Guo:
We have reviewed your amended draft registration statement 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 this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 1 to DRS
Transfer of Cash to and from Our Post-Combination Organization If We Acquire a Company
Based in China, page 10
1.We reissue comment 6 in part. Please describe any restrictions on the transfer of cash
between entities within China after a business combination with a company based in
China.
Enforcement of Civil Liabilities, page 12
2.Please identify each officer and/or director located in China or Hong Kong and disclose
that it will be more difficult to enforce liabilities and judgments on these individuals.
Please also provide disclosure consistent with this section in the risk factor section. We
FirstName LastNameDajiang Guo
Comapany NameAlphaTime Acquisition Corp.
November 29, 2022 Page 2
FirstName LastName
Dajiang Guo
AlphaTime Acquisition Corp.
November 29, 2022
Page 2
note the final risk factor on page 62.
You may contact Todd Schiffman at 202-551-3491 or John Dana Brown at 202-551-3859
with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance