TEXT-EXTRACT 2 filename2.txt 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 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, FirstName LastNameJim Xu Division of Corporation Finance Comapany NameLOBO EV TECHNOLOGIES LTD Office of Manufacturing January 12, 2024 Page 2 cc: Lawrence Venick FirstName LastName