SEC Comment Letter 0000000000-23-012960 to Lotus Technology Inc. (LOT)
Lotus Technology Inc.
Date: Nov. 29, 2023 · CIK: 0001962746 · Accession: 0000000000-23-012960
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-275001
Letter
United States securities and exchange commission logo November 29, 2023 Qingfeng Feng Chief Executive Officer Lotus Technology Inc. No. 800 Century Avenue Pudong District, Shanghai People's Republic of China Re:Lotus Technology Inc. Amendment No. 1 to Registration Statement on Form F-4 Filed November 15, 2023 File No. 333-275001 Dear Qingfeng Feng: We have reviewed your amended registration statement and have the following comments. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Amendment No. 1 to Registration Statement on Form F-4 filed November 15, 2023 Recent Development of Lotus Tech, page 39 1.Please revise the disclosure in this section to remove any implication that investors should not rely on the information presented. If you choose to disclose preliminary results, you should be able to assert that the actual results are not expected to differ materially from that reflected in the preliminary results. Additionally, revise your disclosures to prominently label as preliminary at the beginning of your discussion. Unaudited Pro Forma Condensed Combined Financial Information, page 326 2.Please revise you reference that the LCAA's unaudited information as of and for the six months ended June 30, 2023 are included elsewhere in the proxy statement/prospectus.
FirstName LastNameQingfeng Feng Comapany NameLotus Technology Inc. November 29, 2023 Page 2 FirstName LastName Qingfeng Feng Lotus Technology Inc. November 29, 2023 Page 2 Please contact Kevin Stertzel at 202-551-3723 or Melissa Gilmore at 202-551-3777 if you have questions regarding comments on the financial statements and related matters. Please contact Thomas Jones at 202-551-3602 or Erin Purnell at 202-551-3454 with any other questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Shu Du, Esq.
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United States securities and exchange commission logo
November 29, 2023
Qingfeng Feng
Chief Executive Officer
Lotus Technology Inc.
No. 800 Century Avenue
Pudong District, Shanghai
People's Republic of China
Re:Lotus Technology Inc.
Amendment No. 1 to Registration Statement on Form F-4
Filed November 15, 2023
File No. 333-275001
Dear Qingfeng Feng:
We have reviewed your amended registration statement and have the following
comments.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Amendment No. 1 to Registration Statement on Form F-4 filed November 15, 2023
Recent Development of Lotus Tech, page 39
1.Please revise the disclosure in this section to remove any implication that investors should
not rely on the information presented. If you choose to disclose preliminary results, you
should be able to assert that the actual results are not expected to differ materially from
that reflected in the preliminary results. Additionally, revise your disclosures to
prominently label as preliminary at the beginning of your discussion.
Unaudited Pro Forma Condensed Combined Financial Information, page 326
2.Please revise you reference that the LCAA's unaudited information as of and for the six
months ended June 30, 2023 are included elsewhere in the proxy statement/prospectus.
FirstName LastNameQingfeng Feng
Comapany NameLotus Technology Inc.
November 29, 2023 Page 2
FirstName LastName
Qingfeng Feng
Lotus Technology Inc.
November 29, 2023
Page 2
Please contact Kevin Stertzel at 202-551-3723 or Melissa Gilmore at 202-551-3777 if
you have questions regarding comments on the financial statements and related matters. Please
contact Thomas Jones at 202-551-3602 or Erin Purnell at 202-551-3454 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Shu Du, Esq.