SecProbe.io

December 21, 2018
Ban Lor
Chief Executive Officer
Powerbridge Technologies Co., Ltd.
1st Floor, Building D2, Southern Software Park
Tangjia Bay, Zhuhai, Guangdong 519080, China
Re:Powerbridge Technologies Co., Ltd.
Amendment No. 2 to
Draft Registration Statement on Form F-1
Submitted December 10, 2018
CIK No. 0001754323
Dear Mr. Lor:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 2 to Draft Registration Statement on Form F-1
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 53
1.Please revise your aging of accounts receivable to separately show the amount of current
accounts receivable (i.e. within payment terms).
2.We note from your aging of accounts receivable that approximately 55% of your accounts
receivable as of June 30, 2018 was more than 90 days past due.  As part of your
discussion of liquidity, please disclose the amount of accounts receivable as of June 30,
2018 that was subsequently collected through the most recent practicable date.  In

 FirstName LastNameBan Lor
 Comapany NamePowerbridge Technologies Co., Ltd.
 December 21, 2018 Page 2
 FirstName LastName
Ban Lor
Powerbridge Technologies Co., Ltd.
December 21, 2018
Page 2
addition, please update your December 31, 2017 accounts receivable collection
disclosures to reflect the amounts collected through the most recent practicable date.
3.Your response to comment 9 states that generally you bill customers “20% to 30% of total
fee upon signing the contract, 20% to 30% of total fee upon completion of developing,
implementing and testing the customized applications and the remaining 30% to 50% of
total fee is billed after the customer internally approves the project and signs off the
acceptance form.”  We also note from your response to comment 11 that your four major
government customers representing 59.4% of unbilled accounts receivable as of
December 31, 2017 were not billed as of December 31, 2017 because you needed to
receive full acceptance from ten national government bureaus and from the local
government.  Using language which is similar to that provided in your prior responses,
please revise to more fully disclose your contract billing terms and the multiple levels of
acceptances and the additional performance from the Company that may be required to
bill the final contract amount upon completion of the project.
Notes to Consolidated Financial Statements
Note 2 - Summary of Significant Accounting Policies
Revenue Recognition, page F-12
4.We note your response to comment 9.  Please disclose your typical payment terms with
customers (i.e., 30 days, 60 days).  Tell us when the amounts included in your accounts
receivable balance as of December 31, 2017 were actually collected in relation to the
negotiated payment terms.  In addition, please tell us if there are any penalties for late
payment.
            You may contact Diane Fritz, Staff Accountant, at 202-551-3331 or Melissa Walsh, Staff
Accountant, at 202-551-3224 if you have questions regarding comments on the financial
statements and related matters.  Please contact Donald Field, Attorney-Advisor, at 202-551-3680
or Dietrich King, Attorney-Advisor, at 202-551-8071 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services