SEC Comment Letter 0000000000-23-001130 to LOBO TECHNOLOGIES LTD. (LOBO)
LOBO TECHNOLOGIES LTD.
Date: Feb. 3, 2023 · CIK: 0001932072 · Accession: 0000000000-23-001130
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United States securities and exchange commission logo
February 3, 2023
Jim Xu
Chief Executive Officer
LOBO EV TECHNOLOGIES LTD
Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd
Xinwu District, Wuxi, Jiangsu
People’s Republic of China, 214111
Re:LOBO EV TECHNOLOGIES LTD
Amendment No. 4 to Draft Registration Statement on Form F-1
Submitted January 31, 2023
CIK No. 0001932072
Dear Jim Xu:
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 4 to Draft Registration Statement on Form F-1
Capitalization, page 58
1.Please revise your Capitalization table to include your indebtedness in accordance with
Item 4(a) of Form F-1 and Item 3.B of Form 20-F.
You may contact Heather Clark at (202) 551-3624 or Hugh West at (202) 551-3872 if
you have questions regarding comments on the financial statements and related matters. Please
contact Bradley Ecker at (202) 551-4985 or Geoffrey Kruczek at (202) 551-3641 with any other
questions.
FirstName LastNameJim Xu
Comapany NameLOBO EV TECHNOLOGIES LTD
February 3, 2023 Page 2
FirstName LastName
Jim Xu
LOBO EV TECHNOLOGIES LTD
February 3, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Lawrence Venick