Correspondence 0001493152-24-002883 from LOBO TECHNOLOGIES LTD. (LOBO)
LOBO TECHNOLOGIES LTD.
Date: Jan. 18, 2024 · CIK: 0001932072 · Accession: 0001493152-24-002883
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-270499
Referenced dates: January 12, 2024
Letter
United States Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services Re: LOBO EV TECHNOLOGIES LTD Amendment No. 6 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. 6 to Registration Statement on Form F-1 filed on November 17, 2023 (the “Amendment”) contained in the Staff’s letter dated January 12, 2024 (the “Comment Letter”).
The Company has filed via EDGAR Amendment No. 8 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.
Form F-1 filed January 4, 2024
General
1. We note the changes you made to your disclosure appearing on the cover page, Summary and Risk Factor sections relating to legal and operational risks associated with operating in China and PRC regulations. It is unclear to us that there have been changes in the regulatory environment in the PRC since the amendment that was submitted on November 29, 2023 warranting revised disclosure to mitigate the challenges you face and related disclosures. The Sample Letters to China-Based Companies sought specific disclosure relating to the risk that the PRC government may intervene in or influence your operations at any time, or may exert control over operations of your business, which could result in a material change in your operations and/or the value of the securities you are registering for sale. We remind you that, pursuant to federal securities rules, the term “control” (including the terms “controlling,” “controlled by,” and “under common control with”) as defined in Securities Act Rule 405 means “the possession, direct or indirect, of the power to direct or cause the direction of the management and policies of a person, whether through the ownership of voting securities, by contract, or otherwise.” The Sample Letters also sought specific disclosures relating to uncertainties regarding the enforcement of laws and that the rules and regulations in China can change quickly with little advance notice. We do not believe that your revised disclosure referencing the PRC government’s intent to strengthen its regulatory oversight conveys the same risk. Please restore your disclosures in these areas to the disclosures as they existed in the registration statement as of the November 29, 2023 submission.
Response: The Company has filed the Amendment, which restored the disclosures in these areas to the disclosures as they existed in the registration statement as of the November 29, 2023 submission.
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.
United States Securities and Exchange Commission
January 18, 2024
Page
Please do not hesitate to contact Lawrence Venick at (310) 728-5129 of Loeb & Loeb LLP with any questions or comments regarding this letter.
Very
truly yours,
Loeb
& Loeb LLP
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CORRESP
1
filename1.htm
Loeb
& Loeb LLP
2206-19
Jardine House 1
Connaught
Road Central
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Kong SAR
Main
+852-3923-1111
Fax
+852-3923-1100
January
18, 2024
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. 6 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. 6 to Registration
Statement on Form F-1 filed on November 17, 2023 (the “Amendment”) contained in the Staff’s letter dated January 12,
2024 (the “Comment Letter”).
The
Company has filed via EDGAR Amendment No. 8 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.
Form
F-1 filed January 4, 2024
General
1. We
note the changes you made to your disclosure appearing on the cover page, Summary and Risk
Factor sections relating to legal and operational risks associated with operating in China
and PRC regulations. It is unclear to us that there have been changes in the regulatory environment
in the PRC since the amendment that was submitted on November 29, 2023 warranting revised
disclosure to mitigate the challenges you face and related disclosures. The Sample Letters
to China-Based Companies sought specific disclosure relating to the risk that the PRC government
may intervene in or influence your operations at any time, or may exert control over operations
of your business, which could result in a material change in your operations and/or the value
of the securities you are registering for sale. We remind you that, pursuant to federal securities
rules, the term “control” (including the terms “controlling,” “controlled
by,” and “under common control with”) as defined in Securities Act Rule
405 means “the possession, direct or indirect, of the power to direct or cause the
direction of the management and policies of a person, whether through the ownership of voting
securities, by contract, or otherwise.” The Sample Letters also sought specific disclosures
relating to uncertainties regarding the enforcement of laws and that the rules and regulations
in China can change quickly with little advance notice. We do not believe that your revised
disclosure referencing the PRC government’s intent to strengthen its regulatory oversight
conveys the same risk. Please restore your disclosures in these areas to the disclosures
as they existed in the registration statement as of the November 29, 2023 submission.
Response:
The Company has filed the Amendment, which restored the disclosures in these areas to the disclosures as they existed in the registration
statement as of the November 29, 2023 submission.
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.
United
States Securities and Exchange Commission
January
18, 2024
Page
2
Please
do not hesitate to contact Lawrence Venick at (310) 728-5129 of Loeb & Loeb LLP with any questions or comments regarding this letter.
Very
truly yours,
Loeb
& Loeb LLP
cc: Huajian
Xu