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Skadden,
Arps, Slate, Meagher & Flom

    世達國際律師事務所

    42/F,
    EDINBURGH TOWER, THE LANDMARK

    15
    QUEEN’S ROAD CENTRAL, HONG KONG

    ________

    TEL: (852) 3740-4700

    FAX: (852) 3740-4727

    www.skadden.com

    AFFILIATE OFFICES

    Partners

    -----------

    Geoffrey Chan *

    BOSTON

    Shu Du *

    CHICAGO

    Andrew L. Foster *

    HOUSTON

    Chi T. Steve Kwok *

    LOS ANGELES

    Edward H.P. Lam ¨*

    NEW YORK

    Haiping Li *

    PALO ALTO

    Rory McAlpine ¨

    WASHINGTON, D.C.

    Jonathan B. Stone *

    WILMINGTON

    Paloma P. Wang¨

    -----------

    ¨ (Also Admitted
    in England & Wales)

    BEIJING

    * (Also Admitted in
    New York)

    BRUSSELS

    FRANKFURT

    LONDON

    MUNICH

    PARIS

    SÃO PAULO

    SEOUL

    SHANGHAI

    SINGAPORE

    TOKYO

    TORONTO

October 16, 2023

    VIA EDGAR

    Ms. Erin Purnell

    Mr. Thomas Jones

    Ms. Melissa Gilmore

    Mr. Kevin Stertzel

    Division of Corporation Finance

    Office of Manufacturing

    U.S. Securities and Exchange Commission

    100 F Street, NE

    Washington, D.C. 20549

 Re: Lotus Technology Inc. (CIK No. 0001962746)

Response to the Staff’s Comments on the Draft
Registration

Statement on Form F-4 Confidentially Submitted September 15, 2023

Dear Ms. Purnell, Mr. Jones, Ms. Gilmore and Mr. Stertzel,

On behalf of our client, Lotus Technology Inc.,
a foreign private issuer organized under the laws of the Cayman Islands (the “Company”), we submit to the staff (the
 “Staff”) of the Securities and Exchange Commission (the “Commission”) this letter setting forth
the Company’s responses to the comments contained in the Staff’s letter dated September 29, 2023 on the Company’s
draft registration statement on Form F-4 confidentially submitted on September 15, 2023 (the “Draft Registration Statement”).

Concurrently with the submission of this letter,
the Company is submitting its registration statement on Form F-4 (the “Registration Statement”) and certain exhibits
via EDGAR with the Commission.

U.S. Securities and Exchange Commission

October 16, 2023

Page 2

The Staff’s comments are repeated below
in bold and are followed by the Company’s responses. We have included page references in the Registration Statement where
the language addressing a particular comment appears. Capitalized terms used but not otherwise defined herein have the meanings set forth
in the Registration Statement.

In addition to addressing the comments contained
in the Staff’s letter dated September 29, 2023, the Company has updated the Registration Statement to include its unaudited
interim condensed consolidated and combined financial statements as of June 30, 2023 and for the six months ended June 30,
2023 and 2022  as well as other updates.

Amendment No. 2 to Draft Registration Statement on Form F-4
submitted September 15, 2023

Information about Lotus Tech, page 225

 1. We note
                                            your response to prior comment 4. Please revise the proxy statement/prospectus to include
                                            the information provided in the response letter.

In response to the Staff’s comment, the Company has
revised the disclosure on page 242 of the Registration Statement.

General

 2. We note the changes you made to your disclosure appearing in
                                            Risk Factors 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 filed on July 12, 2023 warranting revised disclosure
                                            to mitigate the challenges you face and related disclosures. The Sample Letters to China-Based
                                            Companies 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 conveys the same risk. Please restore
                                            your disclosures in these areas to the disclosures as they existed in the registration statement
                                            as of the July 12, 2023 amendment.

In response to the Staff’s comment,
the Company has restored the disclosure in Risk Factors relating to legal and operational risks associated with operating in China and
PRC regulations in the Registration Statement.

*	     *	     *

U.S. Securities and Exchange Commission

October 16, 2023

Page 3

If you have any questions regarding the Registration
Statement, please contact the undersigned by phone at +852 3740 4858 or via email at shu.du@skadden.com.

    Very truly yours,

    /s/ Shu Du

    Shu Du

 cc: Qingfeng Feng, Director and Chief Executive Officer, Lotus Technology
                                            Inc.

Alexious Lee, Director and Chief Financial Officer, Lotus
Technology Inc.

Chinta Bhagat, Co-Chief Executive Officer of L Catterton
Asia Acquisition Corp

Scott Chen, Co-Chief Executive Officer of L Catterton
Asia Acquisition Corp

Peter X. Huang, Partner, Skadden, Arps, Slate, Meagher &
Flom LLP

Shu Du, Partner, Skadden, Arps, Slate, Meagher &
Flom LLP

Jesse Sheley, Partner, Kirkland & Ellis
International LLP

Steve Lin, Partner, Kirkland & Ellis
International LLP

Joseph Casey Raymond, Partner, Kirkland &
Ellis International LLP

Justin You Zhou, Partner, Kirkland &
Ellis International LLP

John Fung, Partner, KPMG Huazhen LLP