SEC Comment Letter 0000000000-23-000990 to VCI Global Ltd (VCIG)
VCI Global Ltd
Date: Jan. 31, 2023 · CIK: 0001930510 · Accession: 0000000000-23-000990
AI Filing Summary & Sentiment
File numbers found in text: 333-268109
Letter
United States securities and exchange commission logo January 31, 2023 Victor Hoo Chief Executive Officer VCI Global Limited B03-C-8 Menara 3A KL Eco City, No. 3 Jalan Bangsar 59200 Kuala Lumpur Re:VCI Global Limited Amendment No. 2 to Registration Statement on Form F-1 Filed January 19, 2023 File No. 333-268109 Dear Victor Hoo: We have reviewed your amended registration statement and have the following comment. In our comment, 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 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 comment, we may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our November 21, 2022 letter. Amendment No. 2 to Registration Statement on Form F-1 General 1.We note recent instances of extreme stock price run-ups followed by rapid price declines and stock price volatility seemingly unrelated to company performance following a number of recent initial public offerings, particularly among companies with relatively smaller public floats. Please revise your risk factors section to include a separate risk factor addressing the potential for rapid and substantial price volatility and any known factors particular to your offering that may add to this risk and discuss the risks to investors when investing in stock where the price is changing rapidly. In doing so, please clearly state that such volatility, including any stock-run up, may be unrelated to your
FirstName LastNameVictor Hoo Comapany NameVCI Global Limited January 31, 2023 Page 2 FirstName LastName Victor Hoo VCI Global Limited January 31, 2023 Page 2 actual or expected operating performance and financial condition or prospects, making it difficult for prospective investors to assess the rapidly changing value of your stock. You may contact Blaise Rhodes at 202-551-3774 or Angela Lumley at 202-551-3398 if you have questions regarding comments on the financial statements and related matters. Please contact Alyssa Wall at 202-551-8106 or Dietrich King at 202-551-8071 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Jeffrey P. Wofford, Esq.
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United States securities and exchange commission logo
January 31, 2023
Victor Hoo
Chief Executive Officer
VCI Global Limited
B03-C-8 Menara 3A
KL Eco City, No. 3 Jalan Bangsar
59200 Kuala Lumpur
Re:VCI Global Limited
Amendment No. 2 to Registration Statement on Form F-1
Filed January 19, 2023
File No. 333-268109
Dear Victor Hoo:
We have reviewed your amended registration statement and have the following
comment. In our comment, 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 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 comment, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our November 21, 2022 letter.
Amendment No. 2 to Registration Statement on Form F-1
General
1.We note recent instances of extreme stock price run-ups followed by rapid price declines
and stock price volatility seemingly unrelated to company performance following a
number of recent initial public offerings, particularly among companies with relatively
smaller public floats. Please revise your risk factors section to include a separate risk
factor addressing the potential for rapid and substantial price volatility and any known
factors particular to your offering that may add to this risk and discuss the risks to
investors when investing in stock where the price is changing rapidly. In doing so, please
clearly state that such volatility, including any stock-run up, may be unrelated to your
FirstName LastNameVictor Hoo
Comapany NameVCI Global Limited
January 31, 2023 Page 2
FirstName LastName
Victor Hoo
VCI Global Limited
January 31, 2023
Page 2
actual or expected operating performance and financial condition or prospects, making it
difficult for prospective investors to assess the rapidly changing value of your stock.
You may contact Blaise Rhodes at 202-551-3774 or Angela Lumley at 202-551-3398 if
you have questions regarding comments on the financial statements and related matters. Please
contact Alyssa Wall at 202-551-8106 or Dietrich King at 202-551-8071 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc: Jeffrey P. Wofford, Esq.