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December 13, 2022
Seah Kok Wah
Chief Executive Officer
Angkasa-X Holdings Corp.
11-06, Tower A, Ave 3
Vertical Business Suite
Jalan Kerinchi Bangsar South, 59200, Kuala Lumpur, Malaysia
Re:Angkasa-X Holdings Corp.
Registration Statement on Form F-1
Filed November 15, 2022
File No. 333-268366
Dear Seah Kok Wah:
            We have reviewed your 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 amending your registration statement and providing the
requested information.  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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form F-1 filed November 15, 2022
Cover Page
1.We note that you disclose on page 96 that you are opting out of the extended transition
period for complying with new or revised accounting standards.  Please revise the cover
page to check the box indicating that you have elected not to use the extended transition
period.
2.You disclose that there is no public market for your common stock but that selling
shareholders may offer the shares from time to time through public or private transactions
at prevailing market prices, at prices related to prevailing market prices or at privately
negotiated prices. Please note that an at-the-market resale offering under Rule 415 is not

 FirstName LastNameSeah Kok Wah
 Comapany NameAngkasa-X Holdings Corp.
 December 13, 2022 Page 2
 FirstName LastNameSeah Kok Wah
Angkasa-X Holdings Corp.
December 13, 2022
Page 2
available for registrants that do not have a public market. Please revise your prospectus to
disclose that the selling shareholders will offer and sell their shares at a fixed price
until your shares are listed on a national securities exchange or quoted on the OTC
Bulletin Board, OTCQX, or OTCQB, at which time they may be sold at prevailing market
prices or in privately negotiated transactions.
3.Please disclose prominently on the cover page and in the prospectus summary that See
Unicorn Ventures Limited controls the company through its ownership of 65% of the
company’s shares and will continue to exercise significant control over the company after
this offering. Also disclose that the company’s CEO owns 80% of See Unicorn Ventures
Limited.
Prospectus Summary, page 10
4.Please provide balanced disclosure in your prospectus summary.  Disclose prominently
that you have not yet commenced production level satellite manufacturing and satellite
launch activities, that your auditors have expressed substantial doubt concerning your
ability to continue as a going concern, and that you have incurred minimal revenue and
net losses.
5.In your corporate structure diagram here and on page 78, identify the entity in which
investors will hold shares and the entity in which the company’s operates its business.
Risk Factors
We are heavily dependent on our customers..., page 33
6.Please disclose that two customers accounted for 14.7% and 85.3% in 2021 and two
customers accounted for 7.70% and 92.3% of the total revenue for the six months ended
June 30, 2022. Discuss the material terms of any agreements, including the identity of
each customer. Also file the agreements as exhibits.
Capitalization, page 56
7.Please revise to present the Capitalization and Dilution information as of June 30, 2022.
Dilution, page 57
8.Revise to disclose the net tangible book value per share before the offering.  Refer to Item
506(a) of Regulation S-K.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
60
9.We note your reference to forward-looking statements within the meaning of Section 27A
of the Securities Act and Section 21E of the Exchange Act.  Please be advised that the
safe harbor for forward-looking statements is inapplicable in this context, because the
company is not currently a reporting company. See Section 27A(a)(1) of the Securities

 FirstName LastNameSeah Kok Wah
 Comapany NameAngkasa-X Holdings Corp.
 December 13, 2022 Page 3
 FirstName LastName
Seah Kok Wah
Angkasa-X Holdings Corp.
December 13, 2022
Page 3
Act and Section 21E(a)(1) of the Exchange Act.  Therefore, please delete the references to
the safe harbor or state explicitly that the safe harbor protections do not apply to your
company.
Liquidity and Capital Resource, page 61
10.Please revise to clearly disclose the minimum period of time that you will be able to
conduct planned operations using only currently available capital resources. We refer you
to FRC 501.03(a) and Section IV of SEC Interpretive Release 33-8350.
Business, page 77
11.Throughout the filing you note that you may need to obtain various licenses and that you
have filed for certain approvals, such as on page 12 where you noted that you have filed
for approval for your first satellite spectrum for inclinations and altitudes between 400 and
600 km to meet your transmission requirements.” You also disclose on page 43 that you
may need to maintain or obtain regulatory approvals. Please revise throughout the filing to
clearly disclose the approvals and permissions required to operate and disclose your
expected timeline for obtaining such approvals as well as any factors impacting this
timeline or your ability to ultimately obtain these approvals.
Directors, Management and Corporate Governance, page 99
12.You disclose that Dr. Seah Kok Wah and Dr. Lim Kin Wan are directors and shareholders
of See Unicorn Ventures Limited, owning 80% and 20% of voting power of See Unicorn
Ventures Limited respectively. Please include this information in each of the officer’s
biography. In light of each officer’s other positions, disclose how much time each of Dr.
Seah Kok Wah and Dr. Lim Kin Wan devotes to the company.  Include a risk factor that
discusses any potential conflicts of interest arising from the business activities of your
officers and directors.
Exhibits
13.Please file all material agreements with your VIE as exhibits, including but not limited to,
Exclusive Business Cooperation Agreement, Loan Agreement, Share Pledge Agreement,
Exclusive Option Agreement, and Power of Attorney.
General
14.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communication.

 FirstName LastNameSeah Kok Wah
 Comapany NameAngkasa-X Holdings Corp.
 December 13, 2022 Page 4
 FirstName LastName
Seah Kok Wah
Angkasa-X Holdings Corp.
December 13, 2022
Page 4
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407 or Christine
Dietz, Senior Staff Accountant, at (202) 551-3408 if you have questions regarding comments on
the financial statements and related matters.  Please contact Alexandra Barone, Staff Attorney, at
(202) 551-8816 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Benjamin A. Tan