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January 17, 2023
Qun Lu
Chief Executive Officer
CH AUTO Inc.
6F, Building C
Shunke Building
Shunyi District, Beijing 101200, China
Re:CH AUTO Inc.
Amendment No. 2 to Draft Registration Statement on Form F-4
Submitted December 30, 2022
CIK No. 0001930207
Dear Qun Lu:
            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-4
Questions and Answers About the Business Combination and the Special Meeting
Will I experience dilution as a result of the Business Combination?, page 12
1.Refer to the table on page 12 where you disclose a total of 1,668,000 Class A Ordinary
Shares to be issued to MCAF Initial Shareholders (including rights shares).  Please clarify
if the total should instead be 1,668,500 shares as we note the narrative discussion under
the answer to this question and footnote (5) to the table, indicate this total consists of
1,437,500 Pubco Class A Ordinary Shares to be issued to the Sponsor in exchange for the
Insider Shares, 210,000 shares for MCAF common stock in the Private Placement, and
21,000 shares for the rights in the Private Placement.  Please advise or revise throughout

 FirstName LastNameQun Lu
 Comapany NameCH AUTO Inc.
 January 17, 2023 Page 2
 FirstName LastName
Qun Lu
CH AUTO Inc.
January 17, 2023
Page 2
the filing.

2.It appears the introductory paragraph above the table on page 12 should be revised to
clarify that the scenarios include a Minimum Redemption scenario rather than a No
Redemption scenario, and explain the reasons thereof.  Reference is made to footnote (7)
to the tables on page 46.  It also appears footnotes (1), (2), and (3) should be revised.  In
addition, please disclose the date that the actual redemption of the 2,432,520 shares
occurred, as approved at the special meeting of MCAF stockholders held on December 15,
2022, and include that date in the first bullet point on page 189 and elsewhere where such
discussion is provided.

3.We note your response to comment 1 and reissue. We note that the table refers to "MCAF
Initial Shareholders." By footnote or otherwise, revise the table to clearly provide and/or
define only the sponsor and its affiliates’ total potential ownership interest in the
combined company.
Summary of the Proxy Statement/Prospectus, page 21
4.We note your revisions in response to prior comment 6.  Refer to the sentence that begins
"In light of the foregoing circumstances, the Company's independent registered public
accounting firm has included...the six months ended June 30, 2022 were issued".  Please
clarify that the auditors included an explanatory paragraph expressing substantial doubt in
their report on your December 31, 2021 consolidated financial statements since there is no
auditors' report for the six months ended June 30, 2022.  Please also revise the related
disclosures on pages 62-64, 97-98 and 175.  Further, please clarify in the last sentence
of the top paragraph on page 176 that your auditors issued a going concern paragraph in
their report on your December 31, 2021 and 2020 consolidated financial statements
expressing substantial doubt as to your ability to continue as a going concern.

5.We note your responses to comments 2 and 3 and reissue. Please include the table in the
prospectus summary. The table should provide a detailed sources and uses of funds in
addition to your plan to repay liabilities. For example, the table should (1) state the
amount of the expected proceeds from the Business Combination, including the amount
remaining in the trust account, PIPE financings and any other private financings in
connection with the Business Combination and (2) provide detailed disclosure stating the
amount of proceeds that you intend to allocate to (i) fund operations, (ii) cure loans, debt,
accounts payable and other liabilities in default and (iii) settle lawsuits or satisfy
judgements. Clearly disclose which short-term loans and borrowings that you intend to
repay with proceeds from the Business Combination. Additionally, revise this section to
prominently disclose the total amount of borrowings, accounts payable and other
liabilities currently under default.

 FirstName LastNameQun Lu
 Comapany NameCH AUTO Inc.
 January 17, 2023 Page 3
 FirstName LastName
Qun Lu
CH AUTO Inc.
January 17, 2023
Page 3
6.We note that your disclosure that the recent extension approved by MCAF’s shareholders
led to a redemption of 2,432,520 MCAF’s shares in the amount of $24.5 million.  Please
update your disclosure to reflect the outcome of the special meeting of MCAF’s
stockholders held on December 15, 2022, including the "Background of the Business
Combination" where you should explain the reason the amendments were sought, the
conflicts of interest pertaining to your Sponsor, directors and officer, and the impact on
the transaction.  Additionally, disclose the overall impact to the amount of funds in the
Trust Account (and the amount available for liquidation and/or redemption). Finally,
please make appropriate updates about the terms of the amended and restated certificate of
incorporation and trust agreement and the related party extension loans where disclosed in
your registration statement.
Selected Historical Financial Information of MCAF, page 44
7.Please provide a footnote to the interim balance sheet data to quantify and disclose the
facts and circumstances related to MCAF public stockholders exercising redemption
rights in connection with the extension that resulted in cash redemptions of over $24
million subsequent to September 30, 2022.  Please also disclose and discuss the cash
redemptions in MCAF's MD&A.
Manufacturing, page 141
8.We note your response to prior comment 8. Please elaborate on the milestones needed
to achieve to ramp up your production from 100 vehicles to 9,000 vehicles in 2023.
Please also discuss your projected timeline, anticipated location and funding needed
to establish a new manufacturing facility referenced on page 141.
Offline Sales Network, page 142
9.Please disclose the number of your current brand stores and partner stores.
Unaudited Pro Forma Condensed Combined Financial Statements, page 188
10.Refer to page 191.  In order to allow shareholders to more clearly evaluate the financial
condition of each entity prior to the proposed business combination, it appears you should
revise the pro forma balance sheet to add a column for the cash redemptions that occurred
at MCAF subsequent to the balance sheet data and related subtotal column to
reflect MCAF's historical balances adjusted for the cash redemptions that resulted from
the extension request and occurred after the balance sheet date but prior to the proposed
business combination.  Please refer to Rule 11-02(b)(4) of Regulation S-X.
11.We have reviewed the revisions made in response to prior comments 5 and 13.  In regard
to the disclosures in note 3(8) on page 198, and based on the disclosures on page 117, it
remains unclear how you determined it is most probable that CH-Auto (Hong Kong)
Limited will directly own no less than ninety percent (90%) of the then-issued and
outstanding equity interests CH-AUTO TECH as a result of the Reorganization, absent

 FirstName LastNameQun Lu
 Comapany NameCH AUTO Inc.
 January 17, 2023 Page 4
 FirstName LastNameQun Lu
CH AUTO Inc.
January 17, 2023
Page 4
binding agreements with shareholders or a provision the Reorganization will not occur if
shareholders holding greater than 10% in equity interests elect not to exchange their
interests.  Please clarify or revise.  In regard to the pro forma financial statements, please
also address the following:
•Given CH-AUTO TECH shareholders can elect to exchange, maintain or sell their
equity interests in CH-AUTO TECH as a result of the Reorganization under
Approaches I, II or III, as described on page 117, more fully explain how you
determined the pro forma financial statements appropriately reflect the range of
possible results as required by Rule 11-02(a)(10) of Regulation S-X;
•Explain why the non-controlling interest has no impact on the annual and interim pro
forma statements of operations; and
•Explain if and how the Advisors Shares disclosed on page 12 are accounted for in the
pro forma financial statements.

Compensation of Directors and Executive Officers, page 210
12.Please update your compensation disclosure to reflect the fiscal year ended December 31,
2022.
Index to Consolidated Financial Statements
CH AUTO Inc., page F-1
13.We have reviewed the revisions made in response to prior comment 15.  We note the
auditors' reports for CH AUTO Inc. included on pages F-52 and F-60 appear to be
duplicative, except as to the auditors' name as signed and the firm's letterhead.  In this
regard, the auditors' report on page F-52 covers the period as of April 30, 2022 and for the
period from January 25, 2022 through April 30, 2022, and is signed by Marcum
Bernstein & Pinchuk LLP, whereas the auditors' report on page F-60 covers the same
period and is signed by Marcum Asia CPAs LLP (Formerly Marcum Bernstein & Pinchuk
LLP).  Please include only one auditors' report for this period in the next
amendment.  Further, tell us the consideration given to instead referring to the audit firm
as Marcum Asia CPAs LLP (Formerly Marcum Bernstein & Pinchuk LLP) throughout the
filing, such as on pages 22 and 80, and also under Experts on page 254 and in the Exhibit
Index listing in Part II.

14.It appears you have included audited financial statements of CH Auto Inc. as of April 30,
2022 and for the period of January 25, 2022 through April 30, 2022, along with unaudited
interim financial statements of CH Auto Inc. as of June 30, 2022 and for the period
January 25, 2022 through June 30, 2022.  Please confirm if our understanding is correct
and revise the Index to Consolidated Financial Statements for CH Auto Inc. on page F-1
to remove the line item for inclusion of an auditors' report for the June 30, 2022 unaudited
interim financial statements.

 FirstName LastNameQun Lu
 Comapany NameCH AUTO Inc.
 January 17, 2023 Page 5
 FirstName LastName
Qun Lu
CH AUTO Inc.
January 17, 2023
Page 5
Index to Consolidated Financial Statements
Mountain Crest Acquisition Corp. IV, page F-2
15.Under the listing of the Unaudited Condensed Financial Statements, please clarify that
you have included financial statements for the three and nine months ended September 30,
2022.  Your current disclosure states the three and six months ended September 30, 2022.
This applies to the line items for the statements of operations and changes in
stockholders' (deficit).  For the statements of cash flows line item, please revise to state
for the nine months ended September 30, 2022.

Consolidated Financial Statements - CH-Auto Technology Corporation, page F-4
16.We note the audited financial statements of CH-Auto Technology Corporation, the
registrant's predecessor, are older than 12 months and the filing essentially represents the
registrant's initial public offering; therefore, it appears you may be required to provide
updated annual financial statements and related disclosures pursuant to Item 14 of Form
F-4 and Item 8.A.4 of Form 20-F or, if applicable, provide the representations required by
Instruction 2 to Item 8.A.4 filed in an exhibit to the filing.
General
17.We note your disclosure that MCAF received revenue projections. Please elaborate on the
assumptions underlying the projections. Please tell us whether any other projections were
provided to MCAF.
            You may contact Beverly Singleton at 202-551-3328 or Anne McConnell at 202-551-
3709 if you have questions regarding comments on the financial statements and related
matters.  Please contact Evan Ewing at 202-551-5920 or Asia Timmons-Pierce at 202-551-3754
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing