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SHOREPOWER
TECHNOLOGIES, INC.

5291
NE Elam Young Pkwy.

Suite
160

Hillsboro,
OR 97124

November
3, 2023

Via
Edgar Correspondence

Eranga
Dias, Esq.

Staff
Attorney

Office
of Manufacturing

Division
of Corporation Finance

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

    Re:
    Shorepower
    Technologies, Inc.

    Registration
    Statement on Form S-1

    Filed
    August 24, 2023

    File
    No. 333-274184

Dear
Mr. Dias:

Shorepower
Technologies, Inc. (the “Company”) is transmitting this letter in response to comments received from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) by letter dated September 19, 2023, with respect to the registration
statement on Form S-1 (File No. 333-274184) that was submitted to the Commission on August 24, 2023 (the “Registration Statement”).
This letter is being submitted together with the filing of the Company’s Amendment No. 1 to the Registration Statement on Form
S-1 (“Amendment No. 1”). The numbered paragraphs below correspond to the numbered comments in that letter; the Staff’s
comments are presented in bold italics.

Cover
Page

1. We
                                            note that your common stock is quoted on the OTC Pink Market and that you state in the Plan
                                            of Distribution that the selling stockholders may offer, sell or distribute all or a portion
                                            of the shares of common stock at prevailing market prices or at negotiated prices. Please
                                            note that the OTC Pink Market is not an established public trading market into which a selling
                                            stockholder may offer and sell shares at other than a fixed price. Accordingly, please revise
                                            your cover page disclosure, and make corresponding changes elsewhere in the prospectus, to
                                            disclose a fixed price at which the selling stockholders will offer and sell the shares of
                                            common stock. Refer to Item 501(b)(3) of Regulation S-K.

Response:
We have revised the cover page and made corresponding changes elsewhere in the prospectus to state the fixed price at which the selling
stockholders will offer and sell the shares of common stock.

Eranga
Dias, Esq.

November
3, 2023

Page
2 of 7

  2.
  Please provide support
  for your statement that you operate the largest heavy-duty focused network of electrified parking spaces in North America. In addition,
  please provide more information with respect to your plans to upgrade your 300 electric vehicle charging station connection points
  and your TSE stations. Include a schedule for when these upgrades will occur.

Response:
Being in the industry, we know the players and competition. Although we are fairly certain that we operate the largest heavy-duty focused
network of electrified parking spaces, we are unable to locate third party verifiable proof of this statement. Therefore, we have updated
the disclosure to state that we “operate one of the largest heavy-duty focused network of electrified parking spaces in North America.”
Additionally, we have updated the S-1 to include an anticipated schedule to upgrade the facilities to include electric vehicle charging
stations.

Organizational
History, page 4

  3.
  We note your disclosure
  that under the terms of the merger agreement, “Shorepower now owns 55% of our issued and outstanding shares of common stock.”
  Please explain this statement. For example, if you mean that Mr. Kim and his affiliates now own approximately 55% of your common stock,
  please revise to make this clear.

Response:
We have revised the disclosure to make clear that it is Mr. Kim who owns 55% of Shorepower’s common stock.

Risk
Factors, page 9

  4.
  We note that your risk
  factors discussion is longer than fifteen pages. Please revise your registration statement to add a summary of risk factors section
  that include a series of concise, bulleted or numbered statements that is no more than two pages summarizing the principal factors
  that make an investment in Shorepower or this offering speculative or risky. See Item 105(b) of Regulation S-K.

Response:
We have revised our registration statement to add a summary of our risk factors.

  5.
  We note from your Form
  10-Q for the period ended May 31, 2023 that your management concluded that your disclosure controls and procedures were not effective
  as of the end of the period covered by the report. Please include a risk factor highlighting the risks related to the company’s
  ineffective disclosure controls and procedures and describe any deficiencies and weaknesses identified as part of management’s
  evaluation, including any material weaknesses identified in your internal control over financial reporting. Disclose any associated
  remediation procedures as well as the estimated time frame for resolution.

Response:
We have included a risk factor highlighting the risks related to the company’s ineffective disclosure controls and procedures and
described any deficiencies and weaknesses identified as part of management’s evaluation, including any material weaknesses identified
in its internal control over financial reporting and associated remediation procedures as well as the estimated time frame for their
resolution.

Eranga
                                            Dias, Esq.

November
3, 2023

Page
3 of 7

6. Please
                                            disclose whether you are subject to material cybersecurity risks in your supply chain based
                                            on third-party products, software, or services used in your products, services, or business
                                            and how a cybersecurity incident in your supply chain could impact your business. Discuss
                                            the measures you have taken to mitigate these risks.

Response:
We have included a risk factor stating that we are subject to material cybersecurity risks in our supply chain. We have addressed the
measures taken to mitigate the cybersecurity risks in our supply chain.

  7.
  We note your disclosure
  on page 14 stating that difficult macroeconomic conditions could have a material adverse effect on the demand for your products and
  services. Please update this risk factor if recent inflationary pressures have materially impacted your operations. In this regard,
  identify the types of inflationary pressures you are facing and how your business has been affected. In addition, please update your
  disclosure to identify actions planned or taken, if any, to mitigate inflationary pressures.

Response:
We have updated the risk factor to include results of inflationary pressures and how this affected our business. We also included actions
planned to mitigate future potential inflationary pressures.

Risks
Related to our Securities

Concentration
of ownership among our existing executive officers..., page 27

  8.
  Please revise to clarify
  that Mr. Kim is your sole executive officer and director. Please address potential risks that arise from this arrangement. Please also
  expand your disclosure to state that after the offering, Mr. Kim will hold approximately 83.25% of the voting power of the issued and
  outstanding shares of your capital stock.

Response:
We have revised this risk factor to clarify that Mr. Kim is your sole executive officer and director and addressed the potential risks
that arise from this arrangement. We have also clarified this risk factor to state that after the offering, Mr. Kim will hold approximately
83.25% of the voting power of the issued and outstanding shares of our capital stock.

Eranga
                                            Dias, Esq.

November
3, 2023

Page
4 of 7

Use
of Proceeds, page 29

9. We
                                            note that you intend to use a significant portion of the proceeds from this transaction for
                                            debt reduction purposes. As to the proceeds to be used to discharge indebtedness, revise
                                            your disclosure to set forth the interest rate and maturity of such indebtedness. If the
                                            indebtedness to be discharged was incurred within one year, describe the use of the proceeds
                                            of such indebtedness other than short-term borrowings used for working capital. See Item
                                            504 of Regulation S-K.

Response:
We have disclosed the interest rate and maturity of the three promissory notes that we intend to discharge and have attached them as
exhibits to the prospectus.

  10.
  We note that you intend
  to use proceeds from this offering for acquisitions. To the extent that the proceeds may, or will, be used to finance acquisitions
  of other businesses, revise your disclosure to include the identity of such businesses, if known, or, if not known, the nature of the
  businesses to be sought, the status of any negotiations with respect to the nature of the businesses to be sought, the status of any
  negotiations with respect to the acquisition, and a brief description of such business. See Item 504 of Regulation S-K.

Response:
We have updated the disclosure to include the businesses or types of businesses we are investigating for potential acquisition.
We are also investigating electrical contracting businesses and charging station management (CSM) software technologies for
potential acquisition. An electrical contracting business would allow us to both sell charging stations and install them without having
to use subcontractors.

Selling
Stockholders, page 30

11. For
                                            each selling stockholder included in the table, please identify which selling stockholders
                                            hold shares that are issuable upon the exercise of the warrants. Please provide the number
                                            of warrants held and the number of shares of common stock that would be issued upon conversion.

Response:
We have identified in the table of the Selling Stockholders which ones hold shares that are issuable upon exercise of the warrants, the
number of warrants that each of them holds and the number of shares of common stock that would be issued upon conversion.

Eranga
                                            Dias, Esq.

November
3, 2023

Page
5 of 7

Management’s
Discussion and Analysis of Financial Condition and Results of Operations, page 32

  12.
  Please revise this
  section to substantially expand your management’s discussion and analysis to include information required by Item 303 of Regulation
  S-K. This section should provide disclosure in the form of a discussion and analysis from management’s perspective and should
  not merely contain factual statements about your company and its operations. Provide the discussion and analysis in a format that facilitates
  easy understanding and that supplements, and does not merely duplicate, disclosure already provided in the filing. The objective of
  the discussion and analysis is to provide material information relevant to an assessment of the financial condition and results of
  operations of Shorepower including an evaluation of the amounts and certainty of cash flows from operations and from outside sources.
  A discussion and analysis that meets the requirements of Item 303 of Regulation S-K is expected to better allow investors to view Shorepower
  from management’s perspective.

Response:
We have amended our discussion and analysis to meet the requirements of Item 303 of Regulation S-K to better allow investors to view
Shorepower from a management perspective.

  13.
  Please discuss whether
  supply chain disruptions materially affect your outlook or business goals. Specify whether these challenges have materially impacted
  your results of operations or capital resources and quantify, to the extent possible, how your sales, profits, and/or liquidity have
  been impacted.

Response:
We have discussed the impact of supply chain disruptions on our business and how they have impacted our sales and profits.

Executive
Compensation, page 44

  14.
  We note that you have
  disclosed no compensation in this section. We note however that on pages 32-33, you disclose officer compensation and director compensation
  for the years ended February 28, 2023 and 2022, as well as for the quarters ended May 31, 2023 and 2022. Please advise.

Response:
We have revised the discussion of director compensation paid to Jeff Kim, our President, CEO and Chairman of the Board, to state that
he received director compensation of 500,000 restricted shares of our common stock and 250,00 restricted shares of our common stock for
total non-cash compensation of $48,000.

Employment
and Advisory Agreements, page 45

  15.
  We note that the executive
  employment agreement with Mr. Kim provides that his salary “is subject to the cash flow of the Company as determined by the Board.”
  However, we also note that the “Board consists of one member, Jeff Kim.” Please revise your disclosure here to prominently
  state that Mr. Kim has sole control and decision-making power regarding his salary. In addition, also discuss this as a potential risk
  arising from your management structure in the corresponding risk factor under the Risk Factors section.

Response:
We have revised the disclosure to clearly state that Mr. Kim has sole control and decision-making power regarding his salary and added
this as an additional risk factor under the Risk Factors section.

Eranga
                                            Dias, Esq.

November
3, 2023

Page
6 of 7

Principal
Securityholders, page 47

  16.
  Please revise the table
  to show ownership amounts and percentages of the securities before and after the offering. In addition, it appears that three selling
  stockholders may currently hold more than 5% of your common stock and should be included on the principal securityholder table. Further,
  please consider moving the selling stockholder table to be combined with or to directly follow the principal securityholder table.

Response:
We have revised the table to show ownership amounts and percentages of the securities before and after the offering and added two selling
stockholders as principal securityholders.

Index
to Consolidated Financial Statements, page F-1

  17.
  We note from page F-18
  that the merger between United States Basketball League, Inc and Shurepower LLC was accounted for as a reverse recapitalization, where
  United States Basketball League was treated as the acquired company for financial statement reporting purposes and Shurepower, LLC
  is deemed the accounting predecessor of the merger and is the successor registrant for SEC purposes. You disclose that this means that
  Shurepower, LLC’s financial statements for previous periods will be disclosed in the Company’s future periodic reports
  filed with the SEC. Please revise the filing to include the audited annual financial statements of Shurepower LLC, the predecessor
  company, for the periods required by Rule 8-02 of Regulation S-X (i.e., as of the end of and for each of its most recent two fiscal
  years) and revise your MD&A to discuss those results.

Response:
We have revised the prospectus to add the audited financial statements for Shurepower, LLC for the fiscal years ended December 31, 2020
and December 31, 2021 and revised our MD&A to discuss those results.

  18.
  In addition, revise
  the filing to include pro forma financial information related to the merger transaction as required b