United States securities and exchange commission logo
November 3, 2020
Shang-Chiai Kung
President and Chief Executive Officer
Vivic Corp.
187 E. Warm Springs Road, PMB#B450
Las Vegas, NV 89119
Re: Vivic Corp.
Form 10-KT for the
Transition Period from May 1, 2019 to December 31, 2019
Filed April 2, 2020
Amendment No. 1 to
Form 10-KT
Filed May 15, 2020
File No. 333-219148
Dear Mr. Kung:
We have reviewed your filings 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 these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-KT/A for the Transition Period from May 1, 2019 to December 31,
2019
Cover, page 1
1. We note that you have
used an outdated version of Form 10-K. Please use the most
current version of all
Exchange Act forms in your future filings.
Item 9A. Controls and Procedures, page 31
2. Please amend this
filing to provide management s annual report on internal control over
financial reporting.
Refer to Item 308 of Regulation S-K. We remind you that your
amended filing should
include updated certifications that are currently dated and make
reference to the
amended filing.
Shang-Chiai Kung
FirstName
Vivic Corp.LastNameShang-Chiai Kung
Comapany 3,
November NameVivic
2020 Corp.
November
Page 2 3, 2020 Page 2
FirstName LastName
Signatures, page 36
3. Please revise to have your principal executive officer, principal
financial
officer, controller or principal accounting officer, and at least the
majority of the board of
directors sign the report in their individual capacities. These
signatures should appear in a
second signature block of the signature section. If someone has signed
in more than one
capacity, indicate each capacity in which he or she has signed. Refer
to Instruction (D)(2)
to Form 10-K.
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.
You may contact Abe Friedman at 202-551-8298 or Adam Phippen at
202-551-3336 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Taylor Beech at 202-551-4515 or Erin Jaskot at 202-551-3442 with any
other questions.
Sincerely,
Division of
Corporation Finance
Office of Trade
& Services