TEXT-EXTRACT 2 filename2.txt 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 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, FirstName LastNameVictor Hoo Division of Corporation Finance Comapany NameVCI Global Limited Office of Trade & Services January 31, 2023 Page 2 cc: Jeffrey P. Wofford, Esq. FirstName LastName