CORRESP 1 filename1.htm

 

 

PREVENTION INSURANCE.COM

Suite A No. 79-3

Jalan Metro PerdanaBara 1

Taman Usahawan Kepong

Kuala Lumpor , Malaysia 52000

+60 3 6258 5887

 

November 1, 2016

 

Ms. Dormond Yale

Special Counsel

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:Prevention Insurance.com (“Company”)
Preliminary Information Statement on Schedule 14C
Filed: September 23, 2016
File No. 000-32389

 

Dear Ms. Yale:

This letter is a follow-up to the Company’s letter of October 13, 2016 to your office and is responsive to the Comment Letter from the staff (“Staff”) at the Securities and Exchange Commission dated October 19, 2016 concerning the referenced Preliminary Information Statement of the Company (“Preliminary Information Statement”).

 

As mentioned in our prior responsive letter, we will replace the existing text contained in the Preliminary Information Statement which reads as follows;

 

Amendment to Articles of Incorporation Regarding Name Change

 

On the Effective Date, the Charter Amendment will change our corporate name to AIM BIG Resources, Ltd.  The Company has elected to change its name to reflect the new business direction of the Company and the Company’s plans for the future.”

 

with the following text (revised from our prior responsive letter):

 

Amendment to Articles of Incorporation Regarding Name Change

 

On the Effective Date, the Charter Amendment will change our corporate name to AIM BIG Resources, Ltd. In 1999, the Company changed its name to “Prevention Insurance.com’ to reflect its then current business model of seeking to reduce insurance costs for health and life insurance policies through preventive measures. Thereafter, the Company’s business plan migrated to other insurance related activities. During 2006 fiscal year, the Company ceased these insurance related activities. Since the Company has not been in the insurance business for approximately 10 years, the Company, with approval from its majority shareholders, determined to change its name to AIM BIG Resources, Ltd.

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November 1, 2016

Ms. Dormond Yale

Special Counsel

Securities and Exchange Commission

Page 2.

 

As stated in its quarterly and annual filings with the Securities and Exchange Commission, the Company remains a “shell company” and its principal business objective for the next 12 months and beyond such time will be to achieve long-term growth potential through a combination with a business. As of the date of this filing, the Company has not entered into any letter of intent or formal or definitive agreements with any party, regarding business opportunities for the Company. Moreover, the Company believes that a business combination will not occur at any time prior to February 1, 2017, however, the Company can not predict that such business combination will occur on or about such date or at all, nor can the Company predict the type of business operation or terms and conditions of any such combination.” 

 

As stated above, within the next 120 days from the date of this letter (or 150 days from the date of our Pre 14C), the Company has no “plans, arrangements or understandings to enter into a merger, consolidation, acquisition or similar business transaction.” In addition, even if a business combination were to occur post 120 days, as stated above, the Company can not predict the type of business nor the terms or conditions of a business combination. Given these factors, the Company believes that unlike the text of Note A to Schedule 14A (and/or Item 1 of Schedule 14C), the “item” called for in this information to be acted upon (ie name change) does not “involve other matters” requiring additional disclosure. Indeed, as indicated in our prior response, based upon the above facts and circumstances, the Company does not have information that would be responsive to Items 11, 13 and 14 of Schedule 14A and/or Item 1 of Schedule 14C.

 

If the forgoing is acceptable to the Staff, the Company will promptly file an amended Preliminary Information Statement reflecting the above text.

 

The Company acknowledging that:

- it is responsible for the adequacy and accuracy of the disclosure in the filing;

- staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

- it may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 

Sincerely,

 

/s/ Chee Chau Ng

Chee Chau Ng  

President