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UPLOAD Filing

Workhorse Group Inc.
Date: Sept. 30, 2025 · CIK: 0001425287 · Accession: 0000000000-25-010680

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Document Type
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SEC Posture
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Reasoning

File numbers found in text: 001-37673

Date
September 30, 2025
Author
cc: Arthur McMahon, III
Form
UPLOAD
Company
Workhorse Group Inc.

Letter

Re: Workhorse Group Inc. Preliminary Proxy Statement on Schedule 14A Filed September 22, 2025 File No. 001-37673 Dear Richard Dauch:

September 30, 2025

Richard Dauch Chief Executive Officer Workhorse Group Inc. 3600 Park 42 Drive, Suite 160E Sharonville, Ohio 45241

We have conducted a limited review of your filing and have the following comment.

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Prelimianry Proxy Statement on Schedule 14A filed September 22, 2025 Who will be the controlling stockholder of the Combined Company?, page 5

1. Please disclose the name of the controlling stockholder that will initially own approximately 62.5% of Workhorse. Also, revise the last paragraph on page 54 to disclose the name of the controlling stockholder. In addition, revise the Certain Relationships and Related Party Transactions section beginning on page 190 to disclose the name of the controlling stockholder.

We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please contact Thomas Jones at 202-551-3602 or Erin Purnell at 202-551-3454 with any questions. September 30, 2025 Page 2

Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Arthur McMahon, III

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 September 30, 2025

Richard Dauch
Chief Executive Officer
Workhorse Group Inc.
3600 Park 42 Drive, Suite 160E
Sharonville, Ohio 45241

 Re: Workhorse Group Inc.
 Preliminary Proxy Statement on Schedule 14A
 Filed September 22, 2025
 File No. 001-37673
Dear Richard Dauch:

 We have conducted a limited review of your filing and have the following
comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Prelimianry Proxy Statement on Schedule 14A filed September 22, 2025
Who will be the controlling stockholder of the Combined Company?, page 5

1. Please disclose the name of the controlling stockholder that will
initially own
 approximately 62.5% of Workhorse. Also, revise the last paragraph on
page 54 to
 disclose the name of the controlling stockholder. In addition, revise
the Certain
 Relationships and Related Party Transactions section beginning on page
190 to
 disclose the name of the controlling stockholder.

 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Please contact Thomas Jones at 202-551-3602 or Erin Purnell at
202-551-3454 with
any questions.
 September 30, 2025
Page 2

 Sincerely,

 Division of Corporation Finance
 Office of Manufacturing
cc: Arthur McMahon, III
</TEXT>
</DOCUMENT>