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March 22, 2024
Jeff Kim
Chief Executive Officer
SHOREPOWER TECHNOLOGIES INC.
5291 NE Elam Young Pkwy, Suite 160
Hillsboro, OR 97124
Re:SHOREPOWER TECHNOLOGIES INC.
Amendment No. 4 to Registration Statement on Form S-1
Filed March 18, 2024
File No. 333-274184
Dear Jeff Kim:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a 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 letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our February 23, 2024 letter.
Amendment No. 4 to Registration Statement on Form S-1 filed March 18, 2024
Use of Proceeds, page 31
1.We note that you state that the trading price of your common stock is $0.20 per share. We
note also your disclosure on the cover page that the closing price of your common stock
was $0.06 on March 8, 2024. Please revise to be consistent.
Executive Compensation, page 48
2.Please revise this section to reflect executive compensation as of your most recent fiscal
year end. See Item 402(n) of Regulation S-K.

 FirstName LastNameJeff Kim
 Comapany NameSHOREPOWER TECHNOLOGIES INC.
 March 22, 2024 Page 2
 FirstName LastName
Jeff Kim
SHOREPOWER TECHNOLOGIES INC.
March 22, 2024
Page 2
Experts, page 58
3.Please revise to also indicate that you have included the financial statements of
Shurepower LLC as of and for the years ended December 31, 2022 and 2021,
respectively, in the registration statement, and to reference the auditors whose reports you
have included in reliance upon the authority of such firms as experts in accounting and
auditing.
Exhibit 23.3, page X-1
4.Please provide an updated consent from Olayinka Oyebola & Co. Chartered
Accountants that also indicates that the firm consents to all references to itself included in
this registration statement.
Exhibit 99.1
Financial Statements of Shurepower, LLC., page EX-1
5.We note your response to prior comment 6 indicating that the most recent financial
statements of Shurepower LLC as of and for the year ended December 31, 2021 were
accompanied by an audit report that was dated March 13, 2023.  However, we note that
the report of Olayinka Oyebola & Co. Chartered Accountants is dated February 1, 2023.
Please revise the filing to include the updated audit report. Otherwise, please explain to us
in greater detail the reasons for the revised amounts presented in Amendments 3 and 4 of
the filing, and tell us why an updated auditor's report reflecting the audit of these revised
amounts is not required.
            Please contact Charles Eastman at 202-551-3794 or Martin James at 202-551-3671 if you
have questions regarding comments on the financial statements and related matters. Please
contact Eranga Dias at 202-551-8107 or Erin Purnell at 202-551-3454 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing