SEC Comment Letter 0000000000-23-009794 to Turbo Energy, S.A. (TURB)
Turbo Energy, S.A.
Date: Sept. 5, 2023 · CIK: 0001963439 · Accession: 0000000000-23-009794
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File numbers found in text: 333-273198
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United States securities and exchange commission logo
September 5, 2023
Emilio Cañavate
Chief Financial Officer
Turbo Energy, S.A.
Plaza de América
Number 2, 4B
València, Spain 46004
Re:Turbo Energy, S.A.
Amendment No. 2 to Registration Statement on Form F-1
Filed August 28, 2023
File No. 333-273198
Dear Emilio Cañavate:
We have reviewed your amended registration statement and have the following
comment. In our comment, we may ask you to provide us with information so we may better
understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our 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 these comments, we may have additional comments. Unless we note
otherwise, our references to prior comments are to comments in our August 4, 2023 letter.
Registration Statement on Form F-1 filed on August 28, 2023
Exhibits
1.We note that Titan Partners Group has joined as an underwriter to this transaction and will
be the representative for the underwriters. However, the form of Underwriting Agreement
references only Boustead Securities as sole underwriter and representative. Please provide
the Underwriting Agreement with Titan Partners Group LLC.
FirstName LastNameEmilio Cañavate
Comapany NameTurbo Energy, S.A.
September 5, 2023 Page 2
FirstName LastName
Emilio Cañavate
Turbo Energy, S.A.
September 5, 2023
Page 2
You may contact Eiko Yaoita Pyles at 202-551-3587 or Anne McConnell at 202-551-
3709 if you have questions regarding comments on the financial statements and related
matters. Please contact Sarah Sidwell at 202-551-4733 or Erin Purnell at 202-551-3454 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc: Louis A. Bevilacqua