Correspondence 0001493152-23-043091 from LOBO TECHNOLOGIES LTD. (LOBO)
LOBO TECHNOLOGIES LTD.
Date: Nov. 29, 2023 · CIK: 0001932072 · Accession: 0001493152-23-043091
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-270499
Referenced dates: November 27, 2023
Letter
United States Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services Re: LOBO EV TECHNOLOGIES LTD Amendment No. 4 to Registration Statement on Form F-1 Filed on November 17, 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 Amendment No. 4 to Registration Statement on Form F-1 filed on November 17, 2023 (the “Registration Statement”) contained in the Staff’s letter dated November 27, 2023 (the “Comment Letter”).
The Company has filed via EDGAR Amendment No. 5 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 Form F-1 filed November 17, 2023
Dilution, page 59
1. We note your calculation of net tangible book value in your response. Please note that net tangible book value is generally your tangible assets (total assets less intangible assets and deferred IPO costs) less liabilities. Refer to Section 8300 of the Division’s Financial Reporting Manual and revise accordingly.
Response: The Company has amended pages 59 and 60 of the Amendment in response to the comments. The net tangible book value as of June 30, 2023 of $2,510,665 is calculated as below:
Total assets $ 17,430,279
Minus: Intangible assets, net (1,504,399 )
Minus: Operating lease right-of-use assets, net (389,790 )
Minus: Deferred IPO costs (1,000,672 )
Minus: Total liabilities (12,024,753 )
Net tangible book value $ 2,510,665
Exhibits
2. We note that you filed exhibits 10.13 and 10.14; however, the filed exhibits are in a foreign language. Please file an English translation of the exhibits. Refer to Exchange Act Rule 12b-12(d).
Response: The Company has refiled Exhibits 10.13 and 10.14 in response to the comments.
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
November
29, 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
Amendment
No. 4 to Registration Statement on Form F-1
Filed
on November 17, 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 Amendment No. 4 to Registration
Statement on Form F-1 filed on November 17, 2023 (the “Registration Statement”) contained in the Staff’s letter
dated November 27, 2023 (the “Comment Letter”).
The
Company has filed via EDGAR Amendment No. 5 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 Form F-1 filed November 17, 2023
Dilution,
page 59
1.
We
note your calculation of net tangible book value in your response. Please note that net tangible book value is generally your tangible
assets (total assets less intangible assets and deferred IPO costs) less liabilities. Refer to Section 8300 of the Division’s
Financial Reporting Manual and revise accordingly.
Response:
The Company has amended pages 59 and 60 of the Amendment in response to the comments. The net tangible book value as of June 30,
2023 of $2,510,665 is calculated as below:
Total assets
$ 17,430,279
Minus: Intangible assets, net
(1,504,399 )
Minus: Operating lease right-of-use assets, net
(389,790 )
Minus: Deferred IPO costs
(1,000,672 )
Minus: Total liabilities
(12,024,753 )
Net tangible book value
$ 2,510,665
Exhibits
2.
We
note that you filed exhibits 10.13 and 10.14; however, the filed exhibits are in a foreign language. Please file an English translation
of the exhibits. Refer to Exchange Act Rule 12b-12(d).
Response:
The Company has refiled Exhibits 10.13 and 10.14 in response to the comments.
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