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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)

                                                                    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

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    May 3, 2024

VIA EDGAR

Ms. Sarah
Sidwell

Mr. Geoffrey
Kruczek

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 Draft Registration
Statement

on Form F-1 confidentially submitted on March 8, 2024

Dear Ms. Sidwell and Mr. Kruczek,

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 April 2, 2024 on the Company’s draft registration
statement on Form F-1 confidentially submitted to the Commission on March 8, 2024.

Concurrently with the submission of this letter,
the Company is publicly filing its registration statement on Form F-1 (the “Registration Statement”) and certain exhibits
via EDGAR with the Commission.

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.

U.S. Securities and Exchange Commission

 May 3, 2024

Page 2

In addition to addressing the comments contained
in the Staff’s letter dated April 2, 2024, the Company has included its audited consolidated and combined financial statements and
the financial statements of L Catterton Asia Acquisition Corp as of and for the year ended December 31, 2023 as well as other updates
in the Registration Statement.

Draft Registration Statement on Form F-1 filed
on March 8, 2024

General

 1. Please revise to update your disclosures throughout the filing and address areas that appear to need updating or that present inconsistencies.
Non-exclusive examples of areas where disclosure should be updated are as follows:

• You state on pages 17, 69 and 73
that “[f]uture” resales of the securities issued in connection with the Business Combination may cause the market price of
our securities to drop significantly. This statement should be updated given that this prospectus is facilitating those sales.

In response to the Staff’s comment,
the Company has revised the disclosures on pages 12, 62 and 65 as well as other relevant pages of the Registration Statement.

 2. 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 F-4 that was filed on January 11, 2024 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 your F-4 registration statement as of January 11, 2024.

In response to the Staff’s comment,
the Company has revised the disclosures on the cover page and pages 5, 11, 45 and 50 of the Registration Statement.

*                    *                   *

U.S. Securities and Exchange Commission

 May 3, 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.

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

John Fung, Partner, KPMG Huazhen LLP