SEC Comment Letter 0000000000-23-002690 to LOBO TECHNOLOGIES LTD. (LOBO)
LOBO TECHNOLOGIES LTD.
Date: March 17, 2023 · CIK: 0001932072 · Accession: 0000000000-23-002690
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-270499
Letter
United States securities and exchange commission logo March 17, 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 Registration Statement on Form F-1 Filed on March 13, 2023 File No. 333-270499 Dear Jim Xu: We have reviewed your 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 amending your registration statement and providing the requested information. 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 any amendment to your registration statement and the information you provide in response to these comments, we may have additional comments. 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. Exhibits 2.Please refile your exhibits so they are in a searchable format, as required by Regulation S- T. Please also revise your exhibit index to include Exhibits 99.8-99.10. 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
FirstName LastNameJim Xu Comapany NameLOBO EV TECHNOLOGIES LTD March 17, 2023 Page 2 FirstName LastName Jim Xu LOBO EV TECHNOLOGIES LTD March 17, 2023 Page 2 action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. 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. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Lawrence Venick
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United States securities and exchange commission logo
March 17, 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
Registration Statement on Form F-1
Filed on March 13, 2023
File No. 333-270499
Dear Jim Xu:
We have reviewed your 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 amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
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.
Exhibits
2.Please refile your exhibits so they are in a searchable format, as required by Regulation S-
T. Please also revise your exhibit index to include Exhibits 99.8-99.10.
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
FirstName LastNameJim Xu
Comapany NameLOBO EV TECHNOLOGIES LTD
March 17, 2023 Page 2
FirstName LastName
Jim Xu
LOBO EV TECHNOLOGIES LTD
March 17, 2023
Page 2
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
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.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Lawrence Venick