Correspondence 0001104659-24-002816 from Lotus Technology Inc. (LOT)
Lotus Technology Inc.
Date: Jan. 10, 2024 · CIK: 0001962746 · Accession: 0001104659-24-002816
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 15, 2023
Letter
VIA EDGAR Division of Corporation Finance Office of Manufacturing 100 F Street, NE Washington, D.C. 20549 Re: Lotus Technology Inc. (CIK No. 0001962746) Response to the Staff’s Comments on Amendment No. 2 to Registration Statement on Form F-4 filed December 5, 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 December 15, 2023 on the Company’s registration statement on Form F-4 filed with the Commission on December 5, 2023 (the “Amendment No. 2”).
The Staff’s comments are repeated below in bold and are followed by the Company’s responses. Capitalized terms used but not otherwise defined herein have the meanings set forth in the Amendment No. 2.
U.S. Securities and Exchange Commission
January 10, 2024
Page 2
Amendment No. 2 to Registration Statement on Form F-4 filed December 5, 2023
Summary of the Proxy Statement/Prospectus
Permissions Required from the PRC Authorities for Lotus Tech's Operations, page 35
1. If you will be requesting effectiveness of your Form F-4 registration statement before completing the CSRC process, please confirm in writing that you will notify us promptly of any changes to your disclosure regarding or requested by the CSRC.
The Company acknowledges the Staff’s comment and confirms that the Company will promptly notify the Staff before any changes to the disclosure are made to the registration statement regarding or requested by the CSRC.
* * *
U.S. Securities and Exchange Commission
January 10, 2024
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
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Skadden,
Arps, Slate, Meagher & Flom
Partners
Geoffrey Chan *
Shu Du *
Andrew L. Foster *
Chi T. Steve Kwok *
Edward H.P. Lam ¨*
Haiping Li *
Rory McAlpine ¨
Jonathan B. Stone *
Paloma P. Wang ¨
¨ (Also Admitted in England & Wales)
*
(Also Admitted in New York)
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January 10, 2024
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 Amendment No. 2 to Registration Statement on Form F-4 filed December 5, 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 December 15, 2023 on the Company’s registration statement on Form F-4 filed with the
Commission on December 5, 2023 (the “Amendment No. 2”).
The Staff’s
comments are repeated below in bold and are followed by the Company’s responses. Capitalized terms used but not otherwise defined
herein have the meanings set forth in the Amendment No. 2.
U.S. Securities and Exchange Commission
January
10, 2024
Page 2
Amendment No. 2 to Registration
Statement on Form F-4 filed December 5, 2023
Summary of the Proxy Statement/Prospectus
Permissions Required from the
PRC Authorities for Lotus Tech's Operations, page 35
1. If you will be requesting effectiveness
of your Form F-4 registration statement before completing the CSRC process, please confirm
in writing that you will notify us promptly of any changes to your disclosure regarding or
requested by the CSRC.
The Company acknowledges the
Staff’s comment and confirms that the Company will promptly notify the Staff before any changes to the disclosure are made to the
registration statement regarding or requested by the CSRC.
* * *
U.S. Securities and Exchange Commission
January
10, 2024
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