Response to ASX Price Query
Released
Released
Announcement PDF
29 August 2024
Ms Ramona Seeto
ASX Adviser, Listings Compliance
20 Bridge Street
Sydney NSW 2000
Dear Ms Seeto,
Spacetalk Ltd (‘SPA’): Aware Query
Spacetalk Ltd (SPA or Company) refers to your letter of 28 August 2024 and provides the following
responses:
1. Is SPA aware of any information concerning it that has not been announced to the market
which, if known by some in the market, could explain the recent trading in its securities?
No.
If the answer to question 1 is “yes”:
a) Is SPA relying on Listing Rule 3.1A not to announce that information under Listing
Rule 3.1?
b) Can an announcement be made immediately?
c) If an announcement cannot be made immediately, why not and when is it expected
that an announcement will be made?
Not Applicable.
2. If the answer to question 1 is “no” is there any other explanation that SPA may have for the
recent trading in its securities?
No.
3. If the answer to question1 is “no”, is there any other explanation that SPA may have for the
recent trading in its securities?
No.
4. Please confirm that SPA is complying with the Listing Rules and, in particular, Listing Rule 3.1.
Confirmed.
5. Please confirm that SPA‘s responses to the questions above have been authorised and
approved under its published continuous disclosure policy or otherwise by its board or an
officer of SPA with delegated authority from the board to respond to ASX on disclosure
matters.
Confirmed.
Spacetalk Ltd. (ASX:SPA)
ABN 93 091 351 530
Level 2, 104 Frome St, Adelaide South Australia 5000
www.spacetalkwatch.com
Please do not hesitate to contact me should you wish to discuss further.
Yours sincerely,
Kim Larkin
Company Secretary
Spacetalk Ltd. (ASX:SPA)
ABN 93 091 351 530
Level 2, 104 Frome St, Adelaide South Australia 5000
www.spacetalkwatch.com
28 August 2024
Reference: 98930
Ms Kim Larkin
Head of Corporate Services, Queensland
Boardroom Pty Limited
Dear Ms Larkin
Spacetalk Ltd (‘SPA’): Price – Query
ASX refers to the following:
A. The change in the price of SPA’s securities from a closing price of $0.026 on 27 August 2024 to a closing
price of $0.037 on 28 August 2024.
B. The significant increase in the volume of SPA’s securities traded over this period.
Request for information
In light of this, ASX asks SPA to respond separately to each of the following questions and requests for
information:
1. Is SPA aware of any information concerning it that has not been announced to the market which, if known
by some in the market, could explain the recent trading in its securities?
2. If the answer to question 1 is “yes”.
(a)
Is SPA relying on Listing Rule 3.1A not to announce that information under Listing Rule 3.1?
Please note that the recent trading in SPA’s securities would suggest to ASX that such information
may have ceased to be confidential and therefore SPA may no longer be able to rely on Listing
Rule 3.1A. Accordingly, if the answer to this question is “yes”, you need to contact us
immediately to discuss the situation.
(b)
Can an announcement be made immediately? Please note, if the answer to this question is “no”,
you need to contact us immediately to discuss requesting a trading halt (see below).
(c)
If an announcement cannot be made immediately, why not and when is it expected that an
announcement will be made?
3. If the answer to question 1 is “no”, is there any other explanation that SPA may have for the recent trading
in its securities?
4. Please confirm that SPA is complying with the Listing Rules and, in particular, Listing Rule 3.1.
5. Please confirm that SPA’s responses to the questions above have been authorised and approved under its
published continuous disclosure policy or otherwise by its board or an officer of SPA with delegated
authority from the board to respond to ASX on disclosure matters.
When and where to send your response
This request is made under Listing Rule 18.7. Your response is required as soon as reasonably possible and, in
any event, by no later than 9:30 AM AEST Thursday, 29 August 2024. You should note that if the information
requested by this letter is information required to be given to ASX under Listing Rule 3.1 and it does not fall
within the exceptions mentioned in Listing Rule 3.1A, SPA’s obligation is to disclose the information
ASX Limited [[Listings]]
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‘immediately’. This may require the information to be disclosed before the deadline set out in the previous
paragraph and may require SPA to request a trading halt immediately.
Your response should be sent by e-mail to ListingsComplianceSydney@asx.com.au. It should not be sent
directly to the ASX Market Announcements Office. This is to allow me to review your response to confirm that
it is in a form appropriate for release to the market, before it is published on the ASX Market Announcements
Platform.
Trading halt
If you are unable to respond to this letter by the time specified above, or if the answer to question 1 is “yes”
and an announcement cannot be made immediately, you should discuss with us whether it is appropriate to
request a trading halt in SPA’s securities under Listing Rule 17.1. If you wish a trading halt, you must tell us:
the reasons for the trading halt;
how long you want the trading halt to last;
the event you expect to happen that will end the trading halt;
that you are not aware of any reason why the trading halt should not be granted; and
any other information necessary to inform the market about the trading halt, or that we ask for.
We require the request for a trading halt to be in writing. The trading halt cannot extend past the
commencement of normal trading on the second day after the day on which it is granted. You can find further
information about trading halts in Guidance Note 16 Trading Halts & Voluntary Suspensions.
Suspension
If you are unable to respond to this letter by the time specified above, ASX will likely suspend trading in SPA’s
securities under Listing Rule 17.3.
Listing Rules 3.1 and 3.1A
In responding to this letter, you should have regard to SPA’s obligations under Listing Rules 3.1 and 3.1A and
also to Guidance Note 8 Continuous Disclosure: Listing Rules 3.1 – 3.1B. It should be noted that SPA’s
obligation to disclose information under Listing Rule 3.1 is not confined to, nor is it necessarily satisfied by,
answering the questions set out in this letter.
Release of correspondence between ASX and entity
We reserve the right to release a copy of this letter, your reply and any other related correspondence between
us to the market under Listing Rule 18.7A.
Questions
If you have any questions in relation to the above, please do not hesitate to contact me.
Yours sincerely
ASX Compliance
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ASX Customer Service Centre 131 279 | asx.com.au
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