Correspondence 0001104659-23-114814 from Global Lights Acquisition Corp (GLACF) (CIK 0001897971)
Global Lights Acquisition Corp (GLACF) (CIK 0001897971)
Date: Nov. 6, 2023 · CIK: 0001897971 · Accession: 0001104659-23-114814
AI Filing Summary & Sentiment
File numbers found in text: 333-274645
Referenced dates: October 19, 2023
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CORRESP
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filename1.htm
Global Lights Acquisition Corp
November 6, 2023
Mr. Kibum Park
Division of Corporation Finance
Office of Real Estate and Construction
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C., 20549
Re: Global Lights Acquisition Corp
Draft Registration Statement on Form S-1
Filed September 22, 2023
File No. 333-274645
Dear Mr. Kibum Park:
This letter is in response
to the letter dated October 19, 2023, from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
addressed to Global Lights Acquisition Corp (the “Company,” “we,” and “our”). For ease of reference,
we have recited the Commission’s comments in this response and numbered them accordingly. The amendment to Registration Statement
on Form S-1 (the “Registration Statement”) is being filed to accompany this letter.
Registration Statement on Form S-1
filed September 22, 2023
Cover Page
1. We note that you have identified Valuable Capital Securities as a lead or managing underwriter in the
offering. However, Valuable Capital Securities is not identified in the underwriting table on page 165. Please revise or advise as
appropriate. Refer to Item 501(b)(8)(i) of Regulation S-K. If Valuable Capital Securities will not serve as a lead or managing underwriter
in the offering, please clarify and explain their role on page 165.
Response: We respectfully advise
the Staff that Valuable Capital Securities will not serve as an underwriter in this offering, and we have revised the disclosures on the
cover page and throughout the Registration Statement accordingly.
Management
Directors, Director Nominees and Officers,
page 127
2. We note that Chengzhong Li will serve as your independent director immediately upon the effectiveness
of your registration statement on Form S-1. Please revise, here and elsewhere, to ensure that you provide all of the disclosure required
by Item 401 of Regulation S-K. For example, please ensure that the disclosure regarding Chengzhong Li's experience covers the entire prior
five years.
Response: We respectfully advise
the Staff that we have revised the disclosures on page 5, 99, and 128 of the Registration Statement accordingly.
We appreciate the assistance
the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Arila Zhou, Esq.,
of Robinson & Cole LLP, at (212) 451-2908.
[Signature Page Follows]
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Very truly yours,
By: /s/ Zhizhuang Miao
Zhizhuang Miao
Chief Executive Officer
cc: Arila Zhou, Esq.
Robinson & Cole LLP
[signature page to the SEC response letter]