SEC Comment Letter 0000000000-24-013919 to Captivision Inc. (CAPT, CAPTW) (CIK 0001967478) (CAPT)
Captivision Inc. (CAPT, CAPTW) (CIK 0001967478)
Date: Dec. 17, 2024 · CIK: 0001967478 · Accession: 0000000000-24-013919
AI Filing Summary & Sentiment
Referenced dates: December 12, 2024
Letter
December 17, 2024 Gary R. Garrabrant Chairman and Chief Executive Officer Captivision Inc. 298-42 Chung-buk Chungang-ro Chung-buk Pyeong-taek, Gyounggi, Republic of Korea, 17800 Re:Captivision Inc. Schedule 13D Filed by Gary R. Garrabrant Filed August 6, 2024 File No. 005-94238 Response Letter Dated December 12, 2024 Dear Gary R. Garrabrant: We have conducted a limited review of the above-captioned filing, and have the following additional comment. Please respond to this letter by amending the filing or by providing the requested information. If you do not believe our comment applies to your facts and circumstances or that an amendment is appropriate , please advise us why in a response letter. After reviewing any amendment to the filing and any information provided in response to this comment, we may have additional comments. Schedule 13D Filed August 6, 2024 General We note your response to prior comment 2. Please advise us why Mr. Garrabrant filed a new Schedule 13D on August 6, 2024 instead of continuing to report his beneficial ownership by amending the Schedule 13D he jointly filed on January 2, 2024. In addition, please advise us why the associated Amendment No. 1 to the Schedule 13D filed on August 6, 2024 by Jaguar Global Growth Partners I, LLC omits the information called for by Items 2-6 of Schedule 13D or a cover page for Mr. Garrabrant or any of the other reporting persons identified in the initial Schedule 13D filed on January 2, 2024. Refer to Exchange Act Rule 13d- 1(k)(1)(ii) and the text in Rule 13d-101 of Regulation 13D-G accompanying the asterisk on the facing page of Schedule 13D, which states that the “remainder of this cover page shall be filled out for [...] any subsequent amendment containing 1.
December 17, 2024 Page 2 information which would alter disclosures provided in a prior cover page.”
We remind you that the filing persons are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please direct any questions to Brian Soares at 202-551-3690 or Nicholas Panos at 202-551-3266. Sincerely, Division of Corporation Finance Office of Mergers & Acquisitions
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December 17, 2024
Gary R. Garrabrant
Chairman and Chief Executive Officer
Captivision Inc.
298-42 Chung-buk Chungang-ro Chung-buk
Pyeong-taek, Gyounggi, Republic of Korea, 17800
Re:Captivision Inc.
Schedule 13D Filed by Gary R. Garrabrant
Filed August 6, 2024
File No. 005-94238
Response Letter Dated December 12, 2024
Dear Gary R. Garrabrant:
We have conducted a limited review of the above-captioned filing, and have the
following additional comment.
Please respond to this letter by amending the filing or by providing the requested
information. If you do not believe our comment applies to your facts and circumstances or
that an amendment is appropriate , please advise us why in a response letter.
After reviewing any amendment to the filing and any information provided in
response to this comment, we may have additional comments.
Schedule 13D Filed August 6, 2024
General
We note your response to prior comment 2. Please advise us why Mr. Garrabrant
filed a new Schedule 13D on August 6, 2024 instead of continuing to report his
beneficial ownership by amending the Schedule 13D he jointly filed on January 2,
2024. In addition, please advise us why the associated Amendment No. 1 to the
Schedule 13D filed on August 6, 2024 by Jaguar Global Growth Partners I,
LLC omits the information called for by Items 2-6 of Schedule 13D or a cover page
for Mr. Garrabrant or any of the other reporting persons identified in the
initial Schedule 13D filed on January 2, 2024. Refer to Exchange Act Rule 13d-
1(k)(1)(ii) and the text in Rule 13d-101 of Regulation 13D-G accompanying the
asterisk on the facing page of Schedule 13D, which states that the “remainder of this
cover page shall be filled out for [...] any subsequent amendment containing 1.
December 17, 2024
Page 2
information which would alter disclosures provided in a prior cover page.”
We remind you that the filing persons are responsible for the accuracy and adequacy
of their disclosures, notwithstanding any review, comments, action or absence of action by
the staff.
Please direct any questions to Brian Soares at 202-551-3690 or Nicholas Panos at
202-551-3266.
Sincerely,
Division of Corporation Finance
Office of Mergers & Acquisitions