Correspondence 0001493152-23-008239 from LOBO TECHNOLOGIES LTD. (LOBO)
LOBO TECHNOLOGIES LTD.
Date: March 20, 2023 · CIK: 0001932072 · Accession: 0001493152-23-008239
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-270499
Referenced dates: March 17, 2023
Letter
United States Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services Re: LOBO EV TECHNOLOGIES LTD Registration Statement on Form F-1 Filed on March 13, 2023 File No. 333-270499
Dear Mr. Ecker and Mr. Kruczek:
On behalf of our client, LOBO EV Technologies Ltd. (the “Company”), we respond to the comments of the staff of the Division of Corporation Finance of the Commission (the “Staff”) with respect to the above-referenced Registration Statement on Form F-1 filed on March 13, 2023, (the “Registration Statement”) contained in the Staff’s letter dated March 17, 2023 (the “Comment Letter”).
The Company has filed via EDGAR Amendment No. 1 to the Registration Statement (the “Amendment”), which reflects the Company’s responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained in the Comment Letter is printed below and is followed by the Company’s response. All page references in the responses set forth below refer to the page numbers in the Amendment.
Amendment No. 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.
Response: The Company has amended page 58 of the Registration Statement in response to the comments.
2. Please refile your exhibits so they are in a searchable format, as required by Regulation ST.
Please also revise your exhibit index to include Exhibits 99.8-99.10.
Response: The Company has refiled exhibits 10.1-10.11 in a searchable format in response to the comments. The Company has revised the exhibit index to include Exhibits 99.8-99.10.
Please do not hesitate to contact Lawrence Venick at (310) 728-5129 of Loeb & Loeb LLP with any questions or comments regarding this letter.
Sincerely,
/s/
Loeb & Loeb LLP
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CORRESP
1
filename1.htm
Loeb
& Loeb LLP
2206-19
Jardine House 1
Connaught
Road Central
Hong
Kong SAR
Main
Fax
+852-3923-1111
+852-3923-1100
March
20, 2023
United
States Securities and Exchange Commission
Division
of Corporation Finance
Office
of Trade & Services
100
F Street, N.E.
Washington,
D.C. 20549
Attn:
Bradley Ecker and Geoffrey Kruczek
Re:
LOBO
EV TECHNOLOGIES LTD
Registration
Statement on Form F-1
Filed
on March 13, 2023
File
No. 333-270499
Dear
Mr. Ecker and Mr. Kruczek:
On
behalf of our client, LOBO EV Technologies Ltd. (the “Company”), we respond to the comments of the staff of the Division
of Corporation Finance of the Commission (the “Staff”) with respect to the above-referenced Registration Statement
on Form F-1 filed on March 13, 2023, (the “Registration Statement”) contained in the Staff’s letter dated March
17, 2023 (the “Comment Letter”).
The
Company has filed via EDGAR Amendment No. 1 to the Registration Statement (the “Amendment”), which reflects the Company’s
responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained in the
Comment Letter is printed below and is followed by the Company’s response. All page references in the responses set forth below
refer to the page numbers in the Amendment.
Amendment
No. 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.
Response:
The Company has amended page 58 of the Registration Statement in response to the comments.
2.
Please
refile your exhibits so they are in a searchable format, as required by Regulation ST.
Please
also revise your exhibit index to include Exhibits 99.8-99.10.
Response:
The Company has refiled exhibits 10.1-10.11 in a searchable format in response to the comments. The Company has revised the exhibit
index to include Exhibits 99.8-99.10.
Please
do not hesitate to contact Lawrence Venick at (310) 728-5129 of Loeb & Loeb LLP with any questions or comments regarding this letter.
Sincerely,
/s/
Loeb & Loeb LLP
Loeb
& Loeb LLP
cc:
Huajian Xu
Los
Angeles New York Chicago Nashville Washington, DC San Francisco Beijing Hong Kong www.loeb.com
For
the United States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability
partnership.