SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 9, 2025

Huajian Xu
Chief Executive Officer
LOBO EV Technologies Ltd.
Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd
Xinwu District, Wuxi, Jiangsu
People s Republic of China, 214111

 Re: LOBO EV Technologies Ltd.
 Annual Report on Form 20-F for the Fiscal Year Ended December 31,
2024
 File No. 001-41981
Dear Huajian Xu:

 We have completed our review of your filing. We remind you that the
company and
its management are responsible for the accuracy and adequacy of their
disclosures,
notwithstanding any review, comments, action or absence of action by the staff.

 Sincerely,

 Division of Corporation
Finance
 Office of Manufacturing
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 LAWRENCE
 S. VENICK
 Partner

 2206-19
 Jardine House
 1
 Connaught Place Central
 Hong
 Kong, SAR
 Direct
 Main
 Fax
 Email
 +852.3923.1188
 +852
 3923 1111
 +852
 3923 1100
 lvenick@loeb.com

 Via
EDGAR

 July
8, 2025

 Ms.
Beverly Singleton/Ms. Melissa Gilmore

 Securities
and Exchange Commission

 Division
of Corporation Finance

 Office
of Manufacturing

 Washington,
D.C. 20549

 Re:
 LOBO
 EV Technologies Ltd.

 Annual
Report on Form 20-F for the Fiscal Year Ended December 31, 2024

 Filed
April 28, 2025

 File
No. 001-41981

 Dear
Ms. Beverly Singleton/Ms. Melissa Gilmore:

 On
behalf of LOBO EV Technologies Ltd. (the " Company "), below is the response of the Company to the comments of the staff
of the Division of Corporation Finance (the " Staff ") of the United States Securities and Exchange Commission (the
" Commission ") set forth in the Staff's letter, dated June 27, 2025, regarding the Company's annual report
on Form 20-F (the " Annual Report ") filed with the Commission on June 27, 2025. Concurrently with the submission of
this letter, the Company is filing an amendment No. 1 to the Annual Report (the " Amendment ") and certain exhibits
via EDGAR to the Commission.

 For
your convenience, the Staff's comments are set forth in bold, followed by responses on behalf of the Respondents. Unless otherwise
indicated, all page references in the responses set forth below are to the pages of the clean copy of the Annual Report. Capitalized
terms used but not otherwise defined herein shall have the meanings assigned to such terms in the Annual Report.

 Annual
Report on Form 20-F for the Fiscal Year Ended December 31, 2024

 Item
15. Controls and Procedures, page 80

 1.
 We
 note you have disclosed under this heading that controls and procedures are not required.
 Please revise to include the disclosures required by Item 15(a), Disclosure Controls and
 Procedures, and Item 15(b)(1) through (b)(3), Management's Annual Report on Internal
 Control over Financial Reporting, pursuant to the Form 20-F. As an emerging growth company,
 you are not required to comply with Item 15(b)(4) and Item 15(c) of the Form 20-F with respect
 to an attestation report on internal control over financial reporting by your registered
 public accounting firm. Please also provide the disclosures required by Item 15(d) of the
 Form 20-F. Refer to Instruction 1 to Item 15 of the Form 20-F, where compliance with paragraphs
 (b) and (c) were not required in the first fiscal year you were required to file an annual
 report, or the transition period, but are required to comply in the second annual reporting
 year (i.e., your fiscal year ended December 31, 2024). Please amend your December 31, 2024
 Form 20-F in its entirety to comply, including providing updated Exhibit 12 & 13 Certifications
 from the CEO and CFO. In addition, the Exhibit 12 Certifications should include all disclosures
 for paragraph 4, as we note you currently have omitted the paragraph 4(b) required language.
 We refer you to the Staff's Compliance & Disclosure Interpretations ("C&DIs")
 of Regulation S-K, section 246.13.

 Response:
The Company amended page 80 of the Amendment and refile Exhibit 12 & 13 in response to the Staff's comments.

 2.
 We
 further note from Risk Factors, page 2, that you identified two material weaknesses in internal control over financial reporting.
 Your revised disclosures under Item 15 should also discuss these material weaknesses and any remediation actions or plans you have
 implemented to address the material weaknesses. Please be advised we would anticipate both your conclusions, under Item 15 of the
 Form 20-F, of disclosure controls and procedures and internal control over financial reporting as of December 31, 2024 to be concluded
 as not effective due to the material weaknesses. Refer to Section II.B.3(c) of SEC Release No. 33-8238.

 Response:
The Company amended page 80 of the Amendment in response to the Staff's comments.

 Please
contact the undersigned at (852) 3923-1188 if you have any questions with respect to the response contained in this letter.

 Sincerely,

 /s/
 Lawrence Venick

 Lawrence
 Venick

 Partner

 cc:
 Huajian
 Xu

 Chief
 Executive Officer

 LOBO
 EV Technologies Ltd.

<DOCUMENT>
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<FILENAME>filename2.txt
<TEXT>
 June 27, 2025

Huajian Xu
Chief Executive Officer
LOBO EV Technologies Ltd.
Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd
Xinwu District, Wuxi, Jiangsu
People s Republic of China, 214111

 Re: LOBO EV Technologies Ltd.
 Annual Report on Form 20-F for the Fiscal Year Ended December 31,
2024
 Filed April 28, 2025
 File No. 001-41981
Dear Huajian Xu:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Annual Report on Form 20-F for the Fiscal Year Ended December 31, 2024
Item 15. Controls and Procedures, page 80

1. We note you have disclosed under this heading that controls and
procedures are not
 required. Please revise to include the disclosures required by Item
15(a), Disclosure
 Controls and Procedures, and Item 15(b)(1) through (b)(3), Management's
Annual
 Report on Internal Control over Financial Reporting, pursuant to the
Form 20-F. As
 an emerging growth company, you are not required to comply with Item
15(b)(4) and
 Item 15(c) of the Form 20-F with respect to an attestation report on
internal control
 over financial reporting by your registered public accounting firm.
Please also provide
 the disclosures required by Item 15(d) of the Form 20-F. Refer to
Instruction 1 to Item
 15 of the Form 20-F, where compliance with paragraphs (b) and (c) were
not required
 in the first fiscal year you were required to file an annual report, or
the transition
 period, but are are required to comply in the second annual reporting
year (i.e., your
 fiscal year ended December 31, 2024). Please amend your December 31,
2024 Form
 June 27, 2025
Page 2

 20-F in its entirety to comply, including providing updated Exhibit 12 &
13
 Certifications from the CEO and CFO. In addition, the Exhibit 12
Certifications
 should include all disclosures for paragraph 4, as we note you currently
have omitted
 the paragraph 4(b) required language. We refer you to the Staff's
Compliance
 & Disclosure Interpretations ("C&DIs") of Regulation S-K, section
246.13.

2. We further note from Risk Factors, page 2, that you identified two
material
 weaknesses in internal control over financial reporting. Your revised
disclosures
 under Item 15 should also discuss these material weaknesses and any
remediation
 actions or plans you have implemented to address the material
weaknesses. Please be
 advised we would anticipate both your conclusions, under Item 15 of the
Form 20-F,
 of disclosure controls and procedures and internal control over
financial reporting as
 of December 31, 2024 to be concluded as not effective due to the
material
 weaknesses. Refer to Section II.B.3(c) of SEC Release No. 33-8238.

 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Beverly Singleton at 202-551-3328 or Melissa Gilmore at
202-551-
3777 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

LOBO
EV TECHNOLOGIES LTD.

Gemini
Mansion B 901, i Park, No. 18-17 Zhenze Rd

Xinwu
District, Wuxi, Jiangsu

People’s
Republic of China, 214111

January
23, 2025

VIA
EDGAR & TELECOPY

Attn:
Bradley Ecker

Division
of Corporation Finance

Office
of Manufacturing

U.S.
Securities & Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    RE:
    LOBO
    EV TECHNOLOGIES LTD. (the “Company”)

    Registration
    Statement on Form F-1

    (File
    No. 333-284161) (the “Registration Statement”)

Dear
Mr. Ecker:

The
Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness
of the Registration Statement so that such Registration Statement will become effective as of 5:00 p.m. on January 24,
2025, or as soon thereafter as practicable.

The
Company hereby acknowledges that:

    ●
    Should
    the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare
    the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration
    Statement;

    ●
    The
    action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective,
    does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement;
    and

    ●
    The
    Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
    or any person under the federal securities laws of the United States.

If
there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the
Company may be making an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461
of Regulation C. Such request may be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel,
Loeb & Loeb LLP.

[Signature
page follows]

    Very
    truly yours,

    LOBO
    EV TECHNOLOGIES LTD.

    By:
    /s/
    Huajian Xu

    Name:

    Huajian
    Xu

    Title:
     Chief
    Executive Officer

    2

July 9, 2024
Jim Xu
Chief Executive Officer
LOBO EV TECHNOLOGIES LTD
Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd
Xinwu District, Wuxi, Jiangsu
People’s Republic of China, 214111
Re:LOBO EV TECHNOLOGIES LTD
Draft Registration Statement on Form F-1
Submitted July 5, 2024
CIK No. 0001932072
Dear Jim Xu:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement no later than 48 hours prior to
the requested effective date and time. Please refer to Rules 460 and 461 regarding requests for
acceleration. We remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Bradley Ecker at 202-551-4985 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

March
18, 2024

VIA
EDGAR

United
States Securities and Exchange Commission

100
F. Street, NE

Washington,
DC 20549

    Attn:
    Bradley
    Ecker

    Geoffrey
    Kruczek

    Re:
    LOBO
    EV TECHNOLOGIES LTD.

    Registration
    Statement on Form F-1, as amended

    File
    No. 333-270499

Ladies
and Gentlemen:

As
representative of the several underwriters of the proposed offering of shares of common stock of Lobo EV Technologies Ltd. (the “Company”),
we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness
at 5:00 p.m., Eastern Time, on Wednesday, March 20, 2024, or as soon thereafter as possible.

The
undersigned advise that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as
amended.

[Signature
Page Follows]

    Sincerely,

    Kingswood,
    a division of Kingswood Capital Partners, LLC

    By:
    /s/
    Tyler Bashaw

    Name:
    Tyler
    Bashaw

    Title:
    Director

[Signature
Page to Acceleration Request]

CORRESP
1
filename1.htm

LOBO
EV TECHNOLOGIES LTD.

Gemini
Mansion B 901, i Park, No. 18-17 Zhenze Rd

Xinwu
District, Wuxi, Jiangsu

People’s
Republic of China, 214111

March
18, 2024

VIA
EDGAR & TELECOPY

Attn: Bradley Ecker

Division of Corporation Finance

Office
of Manufacturing

U.S. Securities & Exchange Commission

100
F Street, NE

Washington,
D.C. 20549

    RE:
    LOBO
    EV TECHNOLOGIES LTD. (the “Company”)

    Registration
    Statement on Form F-1

    (File
    No. 333- 270499) (the “Registration Statement”)

Dear
Mr. Ecker:

The
Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness
of the Registration Statement so that such Registration Statement will become effective as of 5:00 p.m. on March 20, 2024, or
as soon thereafter as practicable.

The
Company hereby acknowledges that:

    ●
    Should
    the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare
    the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration
    Statement;

    ●
    The
    action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective,
    does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement;
    and

    ●
    The
    Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
    or any person under the federal securities laws of the United States.

If
there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the
Company may be making an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461
of Regulation C. Such request may be made by an executive officer of the Company or by any attorney from the Company’s U.S. counsel,
Loeb & Loeb LLP.

[Signature
page follows]

    Very
    truly yours,

    LOBO
    EV TECHNOLOGIES LTD.

    By:
    /s/
    Huajian Xu

    Name:
    Huajian
    Xu

    Title:
     Chief
    Executive Officer

    2

CORRESP
1
filename1.htm

                                                                     Loeb
                                            & Loeb LLP

    2206-19
    Jardine House 1

    Connaught
    Road Central

    Hong
    Kong SAR

    Main
                                            +852-3923-1111

                                                                                Fax
                                            +852-3923-1100

January
18, 2024

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

Attn: Bradley Ecker and
Geoffrey Kruczek

Re: LOBO EV TECHNOLOGIES LTD

                                                                                Amendment No. 6 to Registration Statement on Form F-1

                                                                                Filed on November 17, 2023

                                                                                File No. 333-270499

Dear
Mr. Ecker and Mr. Kruczek:

On
behalf of our client, LOBO EV Technologies Ltd. (the “Company”), we respond to the comments of the staff of the Division
of Corporation Finance of the Commission (the “Staff”) with respect to the above-referenced Amendment No. 6 to Registration
Statement on Form F-1 filed on November 17, 2023 (the “Amendment”) contained in the Staff’s letter dated January 12,
2024 (the “Comment Letter”).

The
Company has filed via EDGAR Amendment No. 8 to the Registration Statement (the “Amendment”), which reflects the Company’s
responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained in the
Comment Letter is printed below and is followed by the Company’s response. All page references in the responses set forth below
refer to the page numbers in the Amendment.

Form
F-1 filed January 4, 2024

General

1. 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 amendment that was submitted on November 29, 2023 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 the registration statement as of the November 29, 2023 submission.

Response:
The Company has filed the Amendment, which restored the disclosures in these areas to the disclosures as they existed in the registration
statement as of the November 29, 2023 submission.

    Los
    Angeles New York Chicago Nashville Washington, DC San Francisco Beijing Hong Kong www.loeb.com

    For
    the United States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability
    partnership.

    United
    States Securities and Exchange Commission

    January
    18, 2024

    Page
    2

Please
do not hesitate to contact Lawrence Venick at (310) 728-5129 of Loeb & Loeb LLP with any questions or comments regarding this letter.

Very
truly yours,

Loeb
& Loeb LLP

cc: Huajian
                                            Xu

United States securities and exchange commission logo
January 12, 2024
Jim Xu
Chief Executive Officer
LOBO EV TECHNOLOGIES LTD
Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd
Xinwu District, Wuxi, Jiangsu
People’s Republic of China, 214111
Re:LOBO EV TECHNOLOGIES LTD
Amendment No. 6 to Registration Statement on Form F-1
Filed on November 17, 2023
File No. 333-270499
Dear Jim Xu:
            We have reviewed your amended registration statement and have the following comment.
            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. Unless we note otherwise,
any references to prior comments are to comments in our November 27, 2023 letter.
Form F-1 filed January 4, 2024
General
1.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 amendment that was submitted on November
29, 2023 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

 FirstName LastNameJim Xu
 Comapany NameLOBO EV TECHNOLOGIES LTD
 January 12, 2024 Page 2
 FirstName LastName
Jim Xu
LOBO EV TECHNOLOGIES LTD
January 12, 2024
Page 2
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 the registration statement as of the
November 29, 2023 submission.
            Please contact Heather Clark at 202-551-3624 or Hugh West at 202-551-3872 if you have
questions regarding comments on the financial statements and related matters. Please contact
Bradley Ecker at 202-551-4985 or Geoffrey Kruczek at 202-551-3641 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick

CORRESP
1
filename1.htm

    Loeb
    & Loeb LLP

    2206-19
    Jardine House 1

    Connaught
    Road Central

    Hong
    Kong SAR

    Main

    Fax

    +852-3923-1111

    +852-3923-1100

November
29, 2023

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

100
F Street, N.E.

Washington,
D.C. 20549

Attn:
Bradley Ecker and Geoffrey Kruczek

    Re:
    LOBO
    EV TECHNOLOGIES LTD

    Amendment
    No. 4 to Registration Statement on Form F-1

    Filed
    on November 17, 2023

    File
    No. 333-270499

Dear
Mr. Ecker and Mr. Kruczek:

On
behalf of our client, LOBO EV Technologies Ltd. (the “Company”), we respond to the comments of the staff of the Division
of Corporation Finance of the Commission (the “Staff”) with respect to the above-referenced Amendment No. 4 to Registration
Statement on Form F-1 filed on November 17, 2023 (the “Registration Statement”) contained in the Staff’s letter
dated November 27, 2023 (the “Comment Letter”).

The
Company has filed via EDGAR Amendment No. 5 to the Registration Statement (the “Amendment”), which reflects the Company’s
responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained in the
Comment Letter is printed below and is followed by the Company’s response. All page references in the responses set forth below
refer to the page numbers in the Amendment.

Amendment
No. 4 to Form F-1 filed November 17, 2023

Dilution,
page 59

    1.
    We
    note your calculation of net tangible book value in your response. Please note that net tangible book value is generally your tangible
    assets (total assets less intangible assets and deferred IPO costs) less liabilities. Refer to Section 8300 of the Division’s
    Financial Reporting Manual and revise accordingly.

Response:
The Company has amended pages 59 and 60 of the Amendment in response to the comments. The net tangible book value as of June 30,
2023 of $2,510,665 is calculated as below:

    Total assets
    $ 17,430,279

    Minus: Intangible assets, net
      (1,504,399 )

    Minus: Operating lease right-of-use assets, net
      (389,790 )

    Minus: Deferred IPO costs
      (1,000,672 )

    Minus: Total liabilities
      (12,024,753 )

    Net tangible book value
    $ 2,510,665

Exhibits

    2.
    We
    note that you filed exhibits 10.13 and 10.14; however, the filed exhibits are in a foreign language. Please file an English translation
    of the exhibits. Refer to Exchange Act Rule 12b-12(d).

Response:
The Company has refiled Exhibits 10.13 and 10.14 in response to the comments.

Please
do not hesitate to contact Lawrence Venick at (310) 728-5129 of Loeb & Loeb LLP with any questions or comments regarding this letter.

    Sincerely,

    /s/ Loeb
    & Loeb LLP

    Loeb & Loeb LLP

    cc: Huajian Xu

United States securities and exchange commission logo
November 27, 2023
Jim Xu
Chief Executive Officer
LOBO EV TECHNOLOGIES LTD
Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd
Xinwu District, Wuxi, Jiangsu
People’s Republic of China, 214111
Re:LOBO EV TECHNOLOGIES LTD
Amendment No. 4 to Registration Statement on Form F-1
Filed on November 17, 2023
File No. 333-270499
Dear Jim Xu:
            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. Unless we note otherwise,
any references to prior comments are to comments in our October 13, 2023 letter.
Amendment No. 4 to Form F-1 filed November 17, 2023
Dilution, page 59
1.We note your calculation of net tangible book value in your response.  Please note that net
tangible book value is generally your tangible assets (total assets less intangible assets and
deferred IPO costs) less liabilities.  Refer to Section 8300 of the Division's Financial
Reporting Manual and revise accordingly.
Exhibits
2.We note that you filed exhibits 10.13 and 10.14; however, the filed exhibits are in a
foreign language. Please file an English translation of the exhibits. Refer to Exchange Act
Rule 12b-12(d).

 FirstName LastNameJim Xu
 Comapany NameLOBO EV TECHNOLOGIES LTD
 November 27, 2023 Page 2
 FirstName LastName
Jim Xu
LOBO EV TECHNOLOGIES LTD
November 27, 2023
Page 2
            Please contact Heather Clark at 202-551-3624 or Hugh West at 202-551-3872 if you have
questions regarding comments on the financial statements and related matters. Please contact
Bradley Ecker at 202-551-4985 or Geoffrey Kruczek at 202-551-3641 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick

CORRESP
1
filename1.htm

    Loeb
                                            & Loeb LLP

    2206-19
    Jardine House 1

    Connaught
    Road Central

    Hong
    Kong SAR

    Main

    Fax

    +852-3923-1111

    +852-3923-1100

November
17, 2023

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

100
F Street, N.E.

Washington,
D.C. 20549

Attn:
Bradley Ecker and Geoffrey Kruczek

    Re:
    LOBO
                                            EV TECHNOLOGIES LTD

    Amendment
    No. 3 to Registration Statement on Form F-1

    Filed
    on September 29, 2023

    File
    No. 333-270499

Dear
Mr. Ecker and Mr. Kruczek:

On
behalf of our client, LOBO EV Technologies Ltd. (the “Company”), we respond to the comments of the staff of the Division
of Corporation Finance of the Commission (the “Staff”) with respect to the above-referenced Amendment No. 3 to Registration
Statement on Form F-1 filed on September 29, 2023 (the “Registration Statement”) contained in the Staff’s letter
dated October 13, 2023 (the “Comment Letter”).

The
Company has filed via EDGAR Amendment No. 4 to the Registration Statement (the “Amendment”), which reflects the Company’s
responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained in the
Comment Letter is printed below and is followed by the Company’s response. All page references in the responses set forth below
refer to the page numbers in the Amendment.

Amendment
No. 3 to Form F-1 filed September 29, 2023

Dilution,
page 59

    1.
    Please
    tell us how your net tangible book value at June 30, 2023 of $3,286,985 was determined. Provide us with your computation.

Response:
The Company has amended the number of ordinary shares issued and outstanding to be 6,400,000 as of June 30, 2023 in response to Question
5 of the Comment Letter. Thus, the Capitalization section on page 58, and the Dilution section on pages 59 and 60 of the Amendment are
amended correspondently. The net tangible book value as of June 30, 2023 to $3,286,285 is calculated as below:

    As of June 30, 2023

    Total Equity
    $ 5,405,526

    Minus: Non-controlling interest
      (218,652 )

    Minus: Common stock, par value
      (6,400 )

    Minus: Intangible assets, net
      (1,504,399 )

    Minus: Operating lease right-of-use assets, net
      (389,790 )

    Net tangible book value
    $ 3,286,285

Management’s
Discussion and Analysis of Financial Condition and Results of Operations

Components
of Results of Operations, page 65

    2.
    We
                                            note the second table on page 65 represents units sold, please explain why you reflect the
                                            total with a dollar sign.

Response:
The Company has deleted the dollar sign from the second table on page 65 in response to the comments.

June
30, 2023 Interim Financial Statements

Notes
to Unaudited Interim Condensed Consolidated Financial Statements

1.
Organization and Principal Activities

Reorganization,
page F-6

    3.
    You
                                            disclose that in March 2023, your supplemental agreement with Jiangsu LOBO resulted in additional
                                            consideration of $1,437,646 paid related to the reorganization conducted in March 2022. Given
                                            that a year has passed since the reorganization, it is unclear why you believe the amounts
                                            paid relate to the reorganization and therefore have been reflected retroactively. In this
                                            regard, tell us your consideration of the amounts paid as a dividend and tell us how you
                                            determined the value of $1,437,646 for the shares in the reorganization. Provide us with
                                            the authoritative accounting guidance you used to support your accounting treatment. In addition,
                                            please file your supplemental agreement as part of

    your
    response.

Response:
The Company has amended page F-6 of the Amendment as follows in response to the comments and has filed the supplemental agreement
with the Amendment.

In
March 2023, LOBO HK entered into a supplemental agreement with Jiangsu LOBO’s former shareholders, and agreed the consideration
for the share transfer of Jiangsu LOBO to LOBO HK shall be $1,437,646 (RMB 10,000,000), the registered capital amount of Jiangsu LOBO
since its incorporation in November 2021. The pro-rata amount to each shareholder of Jiangsu LOBO was documented in the initial share
transfer agreement entered in March 2022, when LOBO HK and former Jiangsu LOBO shareholders’ decided the consideration to be zero
at the time. In March 2023, when LOBO HK and former Jiangsu LOBO Shareholders entered into this supplemental agreement, the nature of
the share transfer transaction did not change, it is still an acquisition under common control. The supplemental agreement is part of
the Reorganization process.

Jiangsu
LOBO former shareholders include related parties who are also officers of LOBO current structure , hence acquisition was accounted
for as common control acquisition in accordance with ASC 805-50-45-5. Under the guidance, the current capital structure has been retroactively
presented in prior periods as if such structure existed at that time.

The
reorganization has been treated as a corporate restructuring (reorganization) of entities under common control and thus the current capital
structure has been retroactively presented in prior periods as if such structure existed at that time, and therefore, the consideration
amount of $1,437,646 is retrospectively adjusted as of the beginning of the first period presented in the accompanying consolidated financial
statements.

    4.
    Your
    disclosure in the penultimate paragraph on page F-6 states that you effected a share split which increased your authorized and issued
    shares to 50,000,000. Shareholders then surrendered 44,300,000 shares which were cancelled, leaving 5,700,000 shares issued. Please
    revise to clarify whether you still have 50,000,000 shares authorized with 5,700,000 outstanding or whether you no longer have 50,000,000
    shares authorized. Your disclose on page F-6 and on the balance sheet should be revised to separately state the number of authorized
    shares and issued shares.

Response:
The Company has 50,000,000 ordinary shares authorized, with 6,400,000 ordinary shares issued and outstanding. The Company has amended
Unaudited Interim Condensed Consolidated Balance Sheet on page F-2, Unaudited Interim Condensed Consolidated Statement of Equity on Page
F-4, disclosure on Page F-6, and Footnote 16 on Page F-19 of the Amendment in response to the comments. The Company has also retrospectively
amended the audited Consolidated Balance Sheet on page F-25, Footnote 1 on Page F-29, and Footnote 17 on Page F-44 of the Amendment in
response to the comments.

    5.
    In
    a related matter, you disclose that you issued 700,000 shares to existing shareholders in September 2023 on a pro-rata basis. Please
    revise to retroactively reflect this stock dividend  throughout your filing. Refer to SAB Topic 4C. Your earnings per
    share should also be revised in accordance with ASC 260-10-55-12.

Response:
The Company has amended Unaudited Interim Condensed Consolidated Balance Sheet on Page F-2, Unaudited Interim Condensed Consolidated
Statement of Operations and Comprehensive Income on Page F-3, Unaudited Interim Condensed Consolidated Statement of Equity on Page F-4,
disclosure on Page F-6, and Footnote 16 on Page F-19 of the Amendment in response to the comments. The Company has also retrospectively
amended the audited Consolidated Balance Sheet on page F-25, audited Consolidated Statements of Operations and Comprehensive Income on
page F-26, and Consolidated Statement of Equity on Page F-27, Footnote 1 on Page F-29, and Footnote 17 on Page F-44 of the Amendment
in response to the comments.

General

    6.
    We
    note your added disclosure to page 8 regarding your response to the CSRC on August 15, 2023. Please update this disclosure to discuss
    future filings and communications related to your submission as well as the status of any approval. Also reconcile those additions
    with your disclosure on the cover page that you are “currently in the process of submitting filing materials to the CSRC.

Response:
The Company acknowledges the comments and confirms that it will update this disclosure to discuss future filings and communications
related to our submission as well as the status of any approval. The Company has amended the cover page, pages 8, 43, and 96 of
the Amendment in response to the comments.

Please
do not hesitate to contact Lawrence Venick at (310) 728-5129 of Loeb & Loeb LLP with any questions or comments regarding this letter.

    Sincerely,

    /s/
    Loeb & Loeb LLP

    Loeb
    & Loeb LLP

    cc:
    Huajian Xu

United States securities and exchange commission logo
October 13, 2023
Jim Xu
Chief Executive Officer
LOBO EV TECHNOLOGIES LTD
Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd
Xinwu District, Wuxi, Jiangsu
People’s Republic of China, 214111
Re:LOBO EV TECHNOLOGIES LTD
Amendment No. 3 to Registration Statement on Form F-1
Filed on September 29, 2023
File No. 333-270499
Dear Jim Xu:
            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. Unless we note otherwise,
any references to prior comments are to comments in our March 17, 2023 letter.
Amendment No. 3 to Form F-1 filed September 29, 2023
Dilution, page 59
1.Please tell us how your net tangible book value at June 30, 2023 of $3,286,985 was
determined.  Provide us with your computation.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Components of Results of Operations, page 65
2.We note the second table on page 65 represents units sold, please explain why you reflect
the total with a dollar sign.
June 30, 2023 Interim Financial Statements
Notes to Unaudited Interim Condensed Consolidated Financial Statements

 FirstName LastNameJim Xu
 Comapany NameLOBO EV TECHNOLOGIES LTD
 October 13, 2023 Page 2
 FirstName LastName
Jim Xu
LOBO EV TECHNOLOGIES LTD
October 13, 2023
Page 2
1. Organization and Principal Activities
Reorganization, page F-6
3.You disclose that in March 2023, your supplemental agreement with Jiangsu LOBO
resulted in additional consideration of $1,437,646 paid related to the reorganization
conducted in March 2022.  Given that a year has passed since the reorganization, it is
unclear why you believe the amounts paid relate to the reorganization and therefore have
been reflected retroactively.  In this regard, tell us your consideration of the amounts paid
as a dividend and tell us how you determined the value of $1,437,646 for the shares in the
reorganization.  Provide us with the authoritative accounting guidance you used to support
your accounting treatment. In addition, please file your supplemental agreement as part of
your response.
4.Your disclosure in the penultimate paragraph on page F-6 states that you effected a share
split which increased your authorized and issued shares to 50,000,000.  Shareholders then
surrendered 44,300,000 shares which were cancelled, leaving 5,700,000 shares issued.
Please revise to clarify whether you still have 50,000,000 shares authorized with
5,700,000 outstanding or whether you no longer have 50,000,000 shares authorized.  Your
disclose on page F-6 and on the balance sheet should be revised to separately state the
number of authorized shares and issued shares.
5.In a related matter, you disclose that you issued 700,000 shares to existing shareholders in
September 2023 on a pro-rata basis.  Please revise to retroactively reflect this stock
dividend throughout your filing.  Refer to SAB Topic 4C.  Your earnings per share should
also be revised in accordance with ASC 260-10-55-12.
General
6.We note your added disclosure to page 8 regarding your response to the CSRC on August
15, 2023.  Please update this disclosure to discuss future filings and communications
related to your submission as well as the status of any approval.  Also reconcile those
additions with your disclosure on the cover page that you are "currently in the process of
submitting filing materials to the CSRC."
            Please contact Heather Clark at 202-551-3624 or Hugh West at 202-551-3872 if you have
questions regarding comments on the financial statements and related matters. Please contact
Bradley Ecker at 202-551-4985 or Geoffrey Kruczek at 202-551-3641 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick

CORRESP
1
filename1.htm

    Loeb
                                            & Loeb LLP

    2206-19
    Jardine House 1

    Connaught
    Road Central

    Hong
    Kong SAR

    Main

    Fax

    +852-3923-1111

    +852-3923-1100

March
20, 2023

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

100
F Street, N.E.

Washington,
D.C. 20549

Attn:
Bradley Ecker and Geoffrey Kruczek

    Re:
    LOBO
                                            EV TECHNOLOGIES LTD

    Registration
    Statement on Form F-1

    Filed
    on March 13, 2023

    File
    No. 333-270499

Dear
Mr. Ecker and Mr. Kruczek:

On
behalf of our client, LOBO EV Technologies Ltd. (the “Company”), we respond to the comments of the staff of the Division
of Corporation Finance of the Commission (the “Staff”) with respect to the above-referenced Registration Statement
on Form F-1 filed on March 13, 2023, (the “Registration Statement”) contained in the Staff’s letter dated March
17, 2023 (the “Comment Letter”).

The
Company has filed via EDGAR Amendment No. 1 to the Registration Statement (the “Amendment”), which reflects the Company’s
responses to the comments received by the Staff and certain updated information. For ease of reference, each comment contained in the
Comment Letter is printed below and is followed by the Company’s response. All page references in the responses set forth below
refer to the page numbers in the Amendment.

Amendment
No. 4 to Draft Registration Statement on Form F-1

Capitalization,
page 58

    1.
    Please
    revise your Capitalization table to include your indebtedness in accordance with Item 4(a) of Form F-1 and Item 3.B of Form 20-F.

Response:
The Company has amended page 58 of the Registration Statement in response to the comments.

    2.
    Please
                                            refile your exhibits so they are in a searchable format, as required by Regulation ST.

                                                         Please
also revise your exhibit index to include Exhibits 99.8-99.10.

Response:
The Company has refiled exhibits 10.1-10.11 in a searchable format in response to the comments. The Company has revised the exhibit
index to include Exhibits 99.8-99.10.

Please
do not hesitate to contact Lawrence Venick at (310) 728-5129 of Loeb & Loeb LLP with any questions or comments regarding this letter.

    Sincerely,

    /s/
    Loeb & Loeb LLP

    Loeb
    & Loeb LLP

    cc:
    Huajian Xu

Los
Angeles New York Chicago Nashville Washington, DC San Francisco Beijing Hong Kong www.loeb.com

For
the United States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability
partnership.

United States securities and exchange commission logo
March 17, 2023
Jim Xu
Chief Executive Officer
LOBO EV TECHNOLOGIES LTD
Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd
Xinwu District, Wuxi, Jiangsu
People’s Republic of China, 214111
Re:LOBO EV TECHNOLOGIES LTD
Registration Statement on Form F-1
Filed on March 13, 2023
File No. 333-270499
Dear Jim Xu:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, 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 comments apply 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.
Form F-1
Capitalization, page 58
1.Please revise your Capitalization table to include your indebtedness in accordance with
Item 4(a) of Form F-1 and Item 3.B of Form 20-F.
Exhibits
2.Please refile your exhibits so they are in a searchable format, as required by Regulation S-
T.  Please also revise your exhibit index to include Exhibits 99.8-99.10.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of

 FirstName LastNameJim Xu
 Comapany NameLOBO EV TECHNOLOGIES LTD
 March 17, 2023 Page 2
 FirstName LastName
Jim Xu
LOBO EV TECHNOLOGIES LTD
March 17, 2023
Page 2
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Heather Clark at (202) 551-3624 or Hugh West at (202) 551-3872 if
you have questions regarding comments on the financial statements and related matters. Please
contact Bradley Ecker at (202) 551-4985 or Geoffrey Kruczek at (202) 551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick

United States securities and exchange commission logo
February 3, 2023
Jim Xu
Chief Executive Officer
LOBO EV TECHNOLOGIES LTD
Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd
Xinwu District, Wuxi, Jiangsu
People’s Republic of China, 214111
Re:LOBO EV TECHNOLOGIES LTD
Amendment No. 4 to Draft Registration Statement on Form F-1
Submitted January 31, 2023
CIK No. 0001932072
Dear Jim Xu:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment 4 to Draft Registration Statement on Form F-1
Capitalization, page 58
1.Please revise your Capitalization table to include your indebtedness in accordance with
Item 4(a) of Form F-1 and Item 3.B of Form 20-F.
            You may contact Heather Clark at (202) 551-3624 or Hugh West at (202) 551-3872 if
you have questions regarding comments on the financial statements and related matters. Please
contact Bradley Ecker at (202) 551-4985 or Geoffrey Kruczek at (202) 551-3641 with any other
questions.

 FirstName LastNameJim Xu
 Comapany NameLOBO EV TECHNOLOGIES LTD
 February 3, 2023 Page 2
 FirstName LastName
Jim Xu
LOBO EV TECHNOLOGIES LTD
February 3, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick

United States securities and exchange commission logo
January 18, 2023
Jim Xu
Chief Executive Officer
LOBO EV TECHNOLOGIES LTD
Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd
Xinwu District, Wuxi, Jiangsu
People’s Republic of China, 214111
Re:LOBO EV TECHNOLOGIES LTD
Amendment No. 3 to Draft Registration Statement on Form F-1
Submitted January 9, 2023
CIK No. 0001932072
Dear Jim Xu:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 3 to Draft Registration Statement on Form F-1
Capitalization, page 58
1.Your response to prior comment 6 indicates that the relevant changes were made.
However, we note that the capitalization section still presents your data as of December
31, 2021.  As originally requested, please revise to update your capitalization table to
include the most recent balance sheet data presented in your filing.  The dilution section
should be similarly revised.

 FirstName LastNameJim Xu
 Comapany NameLOBO EV TECHNOLOGIES LTD
 January 18, 2023 Page 2
 FirstName LastName
Jim Xu
LOBO EV TECHNOLOGIES LTD
January 18, 2023
Page 2
Compensation of Directors and Executive Officers, page 120
2.Please update your Compensation of Directors and Executive Officers for the year ended
December 31, 2022.
Related Party Transactions, page 123
3.We note that this section includes "a list of related parties with which the Company has
transactions during the years ended December 31, 2021 and 2020." Please revise to
include information since the beginning of the company’s preceding three financial years
up to the date of the document. Refer to Item 7.B of Form 20-F.
            You may contact Heather Clark at (202) 551-3624 or Hugh West at (202) 551-3872 if
you have questions regarding comments on the financial statements and related matters. Please
contact Bradley Ecker at (202) 551-4985 or Geoffrey Kruczek at (202) 551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick

United States securities and exchange commission logo
December 21, 2022
Jim Xu
Chief Executive Officer
LOBO EV TECHNOLOGIES LTD
Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd
Xinwu District, Wuxi, Jiangsu
People’s Republic of China, 214111
Re:LOBO EV TECHNOLOGIES LTD
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted December 9, 2022
CIK No. 0001932072
Dear Jim Xu:
            We have reviewed your amended draft registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Confidential Draft Registration Statement on Form F-1 submitted December 9, 2022
Our principal shareholders have substantial influence over our company. Their interests may not
be aligned with the interests..., page 50
1.We note your response to our prior comment 3 and reissue. Your revised disclosure, that
your principal shareholders "will beneficially own approximately []% of [y]our
outstanding Ordinary Shares representing more than 50% of the voting power of the
Company," continues to imply that there will be multiple classes of stock outstanding after
this offering, each with different voting rights. If that is not true, please revise to eliminate
that implication. If it is true, revise throughout to discuss the terms of and risks related to
the different classes of stock.

 FirstName LastNameJim Xu
 Comapany NameLOBO EV TECHNOLOGIES LTD
 December 21, 2022 Page 2
 FirstName LastNameJim Xu
LOBO EV TECHNOLOGIES LTD
December 21, 2022
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations
Components of Operations
Revenues, page 65
2.We note your discussion on pages 2-3 ("Brief introduction to our products") where you
identify the various products you offer along with the amount of revenues generated from
sales of such products.  Please revise your MD&A to provide a more detailed and granular
discussion that would provide greater transparency into the material components and
potential variability of your revenues.  For example, your disclosures should:
•identify and quantify each individually significant component of revenues;
•quantify the change in each respective component during each period; and
•discuss the reasons for the increases or decreases in the specific dollar amounts for
each of the components identified.  Supplement your discussion with additional
information that would be meaningful to an investor (e.g., in comparative tabular
format, quantify the number of units sold for the respective reporting periods).
Business, page 97
3.We note your response to our prior comment 5. Please disclose whether and to what
extent you rely on third-party manufacturing for your products. In this regard, we note
your disclosure on page 27 that you "purchase certain key components and raw material,
such as batteries, motors, tires, battery chargers and controllers from external suppliers for
use in [y]our operations and production of products."  Also, as previously requested,
disclose the extent of utilization of your facilities.
Strengthen cost control, page 101
4.We note your response to our prior comment 7. Please revise to expand how you intend to
implement cost control with specific, concrete examples, including how the examples you
provide actually lowered procurement costs.
Related Party Transactions, page 123
5.We note your response to prior comment 9.  Please update the disclosure to be as of the
most recent practicable date.  Currently, your disclosure is as of June 30, 2022, which
more than five months prior to the date of this submission.
General
6.We note your interim financial statements provided in response to prior comment 11.
Please also update all relevant sections throughout the F-1 where financial information is
presented to include this interim financial data.  In this regard, we note your summary
information on page 13, capitalization and dilution should be updated.
7.The first full risk factor on page 23 indicates that your operations have not been materially
and negatively impacted by COVID-related matters during 2022.  Please reconcile with

 FirstName LastNameJim Xu
 Comapany NameLOBO EV TECHNOLOGIES LTD
 December 21, 2022 Page 3
 FirstName LastName
Jim Xu
LOBO EV TECHNOLOGIES LTD
December 21, 2022
Page 3
the disclosures on pages 64-65.  Also update the disclosure in the last two paragraphs on
page 62.
            You may contact Heather Clark at (202) 551-3624 or Hugh West at (202) 551-3872 if
you have questions regarding comments on the financial statements and related matters. Please
contact Bradley Ecker at (202) 551-4985 or Geoffrey Kruczek at (202) 551-3641 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick

United States securities and exchange commission logo
October 26, 2022
Jim Xu
Chief Executive Officer
LOBO EV TECHNOLOGIES LTD
Gemini Mansion B 901, i Park, No. 18-17 Zhenze Rd
Xinwu District, Wuxi, Jiangsu
People’s Republic of China, 214111
Re:LOBO EV TECHNOLOGIES LTD
Draft Registration Statement on Form F-1
Submitted September 29, 2022
CIK No. 0001932072
Dear Jim Xu:
            We have reviewed your draft registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement filed September 29, 2022
Market and Industry Data, page 1
1.We note that the proxy statement/prospectus includes industry data and market data in
various sources. If any of these sources were commissioned by you for use in connection
with the proxy statement/prospectus, please file consents pursuant to Rule 436 of the
Securities Act as exhibits or tell us why you believe you are not required to do so.
Prospectus Summary, page 1
2.Please ensure that the information you provide in your summary is balanced. For example,
we note your substantial market competition and limited operating history. To the extent

 FirstName LastNameJim Xu
 Comapany NameLOBO EV TECHNOLOGIES LTD
 October 26, 2022 Page 2
 FirstName LastNameJim Xu
LOBO EV TECHNOLOGIES LTD
October 26, 2022
Page 2
you cite strengths, review each one and revise as necessary to provide balanced
information, rather than merely listing generalized risk factors at the end of this section.
As a "controlled company" under the rules of the Nasdaq Capital Market,, page 51
3.The first paragraph implies that there will be multiple classes of stock outstanding after
this offering, each with different voting rights.  If that is not true, please revise to
eliminate that implication.  If it is true, revise throughout to discuss the terms of and risks
related to the different classes of stock.
Trend Information, page 69
4.Risk factor disclosure on page 30 of your prospectus identifies inflationary pressures as a
factor that may adversely affect your business and your ability to achieve or maintain
profitability. Please expand your disclosure here and in your discussion on page 76 and
update your applicable risk factor to identify the principal factors contributing to the
inflationary pressures the company has experienced and clarify the resulting impact to the
company. Please also update your disclosure to identify actions planned or taken, if any,
to mitigate inflationary pressures.
Business, page 93
5.Please revise this section to discuss your manufacturing operations in more detail,
including the utilization of your manufacturing facilities. Refer to Item 4.D of Form 20-F.
In this regard, you disclose on page 108 that you have a manufacturing facility, but the
table of employees on the preceding page indicates that you have no employees who
perform manufacturing duties.
6.Please disclose whether and how your business, products, lines of service, projects or
operations are materially impacted by supply chain disruptions, especially in light of
Russia's invasion of Ukraine or in light of the effectiveness of the UFLPA. For example,
discuss whether you have or expect to:
•suspend the production, purchase, sale or maintenance of certain items due to a lack
of raw materials, parts, or equipment; inventory shortages; reduced headcount; or
delayed projects;
•experience labor shortages that impact your business;
•experience cybersecurity attacks in your supply chain;
•experience higher costs due to constrained capacity or increased commodity prices or
challenges sourcing materials (e.g., nickel, palladium, neon, cobalt, iron, platinum or
other raw material sourced from Russia, Belarus, or Ukraine or cotton, polysilicon,
lithium, nickel, manganese, beryllium, copper, gold or other raw material sourced
from Western China);
•experience surges or declines in consumer demand for which you are unable to
adequately adjust your supply;
•be unable to supply products at competitive prices or at all due to export restrictions,

 FirstName LastNameJim Xu
 Comapany NameLOBO EV TECHNOLOGIES LTD
 October 26, 2022 Page 3
 FirstName LastNameJim Xu
LOBO EV TECHNOLOGIES LTD
October 26, 2022
Page 3
sanctions, tariffs, trade barriers, or political or trade tensions among countries; or
•be exposed to supply chain risk in light of Russia’s invasion of Ukraine, the
effectiveness of the UFLPA and/or related geopolitical tension or have sought to “de-
globalize” your supply chain.
Explain whether and how you have undertaken efforts to mitigate the impact and where
possible quantify the impact to your business.
Strengthen cost control, page 97
7.Please revise this section to provide specific, concrete disclosure about how you intend to
implement cost control instead of vague statements like "the innovation of internal
management and the optimization of process flow."
Foreign Private Issuer Exemption, page 116
8.Please revise to state clearly and explicitly whether you will rely on the home country
practices discussed in this section.
RELATED PARTY TRANSACTIONS, page 120
9.We note your amounts due from related parties. Please update your disclosure in this
section to be as of the most recent practicable date.
Voting Rights, page 123
10.Please clarify what you mean by "the date of deposit of the requisition."
Financial Statements, page F-1
11.Please revise to include updated financial statements in accordance with Item 4A(b)(2) of
Form F-1 and Item 8.A.5 of Form 20-F.

Notes to Consolidated Financial Statements
7. Prepaid Expenses and Other Current Assets, page F-17
12.Please tell us the nature of the "advances to employees."  Note that Exchange Act Section
13(k)(1) prohibits public companies from extending or maintaining credit in the form of
personal loans to or for any director or executive officer.  To the extent necessary, disclose
the action that will be taken to ensure this arrangement will be extinguished prior to the
closing of the offering, or tell us why this provision does not apply to this loan.  Please
provide the same information with regard to loans to the CEO, Huajian Xu per note 15 on
page F-21. Please also revise your disclosure on page 120.
9. Intangible Assets, Net, page F-18
13.We note significant  increases to your capitalized software during 2021.  Please revise to

 FirstName LastNameJim Xu
 Comapany NameLOBO EV TECHNOLOGIES LTD
 October 26, 2022 Page 4
 FirstName LastNameJim Xu
LOBO EV TECHNOLOGIES LTD
October 26, 2022
Page 4
address the following:
•Identify whether your statement concerning capitalized software for internal use that
had not been completed applies to the purchased software or capitalized software
development costs.
•Clarify if your capitalized software development costs are in the preliminary project
stage or the application development stage and how you determined capitalization
was appropriate.
Refer to ASC 350-40-25.
17. Equity, page F-23
14.We note from (a) that you issued 50,000 shares of common stock in exchange for the
ownership in Jiangsu Lobo.  Please address the following:
•Clarify what is meant by "ownership" in Jiangsu Lobo (e.g., common stock).
•Clarify why a subscription receivable was recorded as still collectible considering
you received ownership in Jiangsu Lobo and paid for such ownership with 50,000
shares of your common stock.  It is unclear what the unrecovered consideration
represents given that the consideration appears to be ownership in Jiangsu.
Exhibits
15.Please remove the filing fee table from your cover page and file it as an exhibit to this
registration statement. Refer to Item 601(b)(107) of Regulation S-K.
16.Please file the agreements mentioned on page 112 and any material lease agreements as
exhibits to your registration statement or explain why you are not required to do so.
17.Exhibit 23.4 refers to an Exhibit 8.3, but no such exhibit is listed in your exhibit index.
Exhibits 8.1 and 8.2 are also not listed.  Please revise or advise.
General
18.Please remove the exclusion of Hong Kong and Macau from your definition of "China" or
the "PRC."
19.Please revise to clarify whether you offer independently or your products include in-
vehicle entertainment, particularly given the industry data you include on page 84.
            You may contact Heather Clark at (202) 551-3624 or Hugh West at (202) 551-3872 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Bradley Ecker at (202) 551-4985 or Geoffrey Kruczek at (202) 551-3641 with any other
questions.
Sincerely,

 FirstName LastNameJim Xu
 Comapany NameLOBO EV TECHNOLOGIES LTD
 October 26, 2022 Page 5
 FirstName LastName
Jim Xu
LOBO EV TECHNOLOGIES LTD
October 26, 2022
Page 5
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick