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                            July 7, 2020

       Jianhui Ye
       Chief Executive Officer
       EZGO Technologies Ltd.
       Building A, Floor 5,
       Changzhou Institute of Dalian University of Technology
       Science and Education Town
       Wujin District, Changzhou City
       Jiangsu, China 213164

                                                        Re: EZGO Technologies
Ltd.
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted June 25,
2020
                                                            CIK No. 0001806904

       Dear Mr. Ye:

             We have reviewed your amended draft offering 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 offering statement or publicly filing your offering
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 any amendment
       to your draft offering statement or filed offering statement and the
information you provide in
       response to these comments, we may have additional comments.

       Amendment No. 1 to Draft Registration Statement on Form F-1 submitted
June 25, 2020

       As a company incorporated in the BVI . . .,, page 25

   1.                                                   We note your response
to prior comment four; however, the disclosures to which you refer
                                                        relate to matters under
the federal securities laws, not corporate governance exemptions
                                                        for the exchange on
which you intend to list. Please revise to disclose the exemptions you
                                                        will be permitted to
follow, even if you do not currently intend to utilize them.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 42
 Jianhui Ye
EZGO Technologies Ltd.
July 7, 2020
Page 2
2.    We have reviewed your response to prior comment ten. As previously
requested and as
      provided in your response, please enhance your disclosure to quantify any
amounts
      included in inventory, advances to suppliers, and property and equipment
related to
      electric bikes that do not meet new national safety standards for
electric bikes in the PRC
      that are recorded in your most recent balance sheet. Please also disclose
and discuss how
      you assessed these assets for impairment.
Net Revenues, page 43

3.    We have reviewed your response to prior comment nine. In regard to the
revenue you
      recognized related to battery cell trading, please revise your
disclosures to explain how the
      amount of your fee was determined (i.e. was it based on the quantity of
battery cells sold,
      the dollar value of battery cells sold or some other measure) and
identify the party who
      paid you the fee (i.e. the seller or buyer). Please also provide
investors with a better
      understanding of your future expectations regarding your trading
business, including
      whether the revenue you recognized in FY 2019 related to one or multiple
transactions
      and how you identify potential sellers and buyers.
Financial Statements for the Years Ended September 30, 2019 and 2018, page F-1

4.    Please provide interim financial statements and related disclosures to
the extent required
      by Item 4 of Form F-1 and Item 8 of Form 20-F.
Note 17. Subsequent Events, page F-34

5.    We have reviewed your response to prior comment 31. As previously
requested, please
      enhance your disclosure to disclose the actual date through which
subsequent events have
      been evaluated. Refer to ASC 855-10-50-1.
       You may contact Jeff Gordon at (202) 551-3866 or Anne McConnell, Senior
Accountant, at (202) 551-3709 if you have questions regarding comments on the
financial
statements and related matters. Please contact Geoff Kruczek at (202) 551-3641
or Jay Ingram,
Legal Branch Chief, at (202) 551-3397 with any other questions.



                                                            Sincerely,
FirstName LastNameJianhui Ye
                                                            Division of
Corporation Finance
Comapany NameEZGO Technologies Ltd.
                                                            Office of
Manufacturing
July 7, 2020 Page 2
cc:       Richard Anslow, Esq.
FirstName LastName