SB
TECHNOLOGY HOLDINGS, INC.
(formerly
VG Life Sciences, Inc.)
447
Broadway, 2nd Floor, Unit 103
New
York, NY 10013
Telephone:
877-646-4833 ● Email: pubcodirector@gmail.com
May
4, 2026
VIA
EDGAR
U.S.
Securities and Exchange Commission
Division
of Corporation Finance
Office
of the Chief Counsel
100
F Street, NE
Washington,
DC 20549
Re:
SB Technology Holdings, Inc. (formerly VG Life Sciences, Inc.)
CIK
No. 0001091326
Form
10-12G filed March 6, 2026
Accession
No. 0001493152-26-009077
Commission
File No. 000-26875
Ladies
and Gentlemen:
On
behalf of SB Technology Holdings, Inc., a Florida corporation (formerly known as VG Life Sciences, Inc.) (the “Company”),
and pursuant to the discretionary authority of the staff of the Division of Corporation Finance, the Company hereby respectfully requests
that the U.S. Securities and Exchange Commission (the “Commission”) consent to the withdrawal of the Company’s Registration
Statement on Form 10-12G (the “Registration Statement”), filed with the Commission on March 6, 2026 under Accession No. 0001493152-26-009077,
together with all exhibits thereto, effective as of the date hereof.
The
Company is requesting the withdrawal of the Registration Statement because, after further internal review, the Company has determined
that it is not yet ready to file an amended Form 10-12G. The Company intends to refile a registration statement on Form 10 at such time
as it is in a position to provide complete and accurate disclosure to the Commission and to investors.
The
Company confirms that no securities have been sold pursuant to or in reliance upon the Registration Statement. The Registration Statement
has not yet become effective, and the Company is submitting this request prior to the date on which the Registration Statement would
otherwise become effective by operation of Section 12(g)(1) of the Securities Exchange Act of 1934, as amended.
Accordingly,
the Company respectfully requests that the staff of the Division of Corporation Finance acknowledge the withdrawal of the Registration
Statement at the staff’s earliest convenience. Should the Commission have any questions or require additional information regarding
this request, please contact the undersigned at the address, telephone number, or email address shown above.
The
Company appreciates the staff’s consideration of this request.
Respectfully
submitted,
| SB
TECHNOLOGY HOLDINGS, INC. |
|
| |
|
|
| By:
|
/s/
Paul Strickland |
|
| Name:
|
Paul
Strickland |
|
| Title:
|
Director
and Secretary |
|
cc:
Board of Directors, SB Technology Holdings, Inc.
