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                             October 19, 2021

       Laurin Hahn
       Co-Chief Executive Officer
       Sono Group N.V.
       Waldmeisterstra  e 76
       80935 Munich, Germany

                                                        Re: Sono Group N.V.
                                                            Amendment No. 2 to
Confidential Draft Registration Statement on Form F-1
                                                            Submitted September
20, 2021
                                                            CIK No. 0001840416

       Dear Mr. Hahn:

             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.

       Draft Registration Statement on Form F-1 filed September 20, 2021

       Financial Statements, page F-1

   1.                                                   We note your responses
to prior comments 7 and 9; however it is not clear to us what the
                                                        terms and conditions of
your customer reservations are or whether you believe a customer
                                                        reservation represents
a binding purchase agreement. Please explain to us the terms and
                                                        conditions of your
customer reservations and explain if/how you determined whether a
                                                        customer reservation
represents a binding purchase agreement. We also note your
                                                        reference to IFRS 15.12
which indicates that (i) a contract with a customer does not exist
                                                        if each party to the
contract has the unilateral enforceable right to terminate a wholly
                                                        unperformed contract
without compensating the other party and that (ii) a contract is
                                                        wholly unperformed if
both of the following criteria are met: (a) the entity has not yet
 Laurin Hahn
Sono Group N.V.
October 19, 2021
Page 2
      transferred any promised goods or services; and (b) the entity has not
yet received     any
      consideration in exchange for promised goods or services. Although you
indicate, in the
      case of the advance payments, you have received considerations from the
customer, it
      appears to us that essentially all the advance payments you have received
will be fully
      refundable without penalty before you anticipate you will have the
ability to perform
      under these agreements and, currently, it is not clear you will have the
ability to perform.
      Since it appears your customers may have a unilateral enforceable right
to terminate a
      customer reservation, without penalty, please more fully explain to us
how you considered
      these factors in your determination that your situation is comparable to
a stand-ready
      obligation as described in IFRS 15.BC50 resulting in a partially
performed IFRS 15
      contract.

        You may contact Andi Carpenter at (202) 551-3645 or Anne McConnell 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 Asia Timmons-Pierce
at (202) 551-
3754 with any other questions.



                                                            Sincerely,
FirstName LastNameLaurin Hahn
                                                            Division of
Corporation Finance
Comapany NameSono Group N.V.
                                                            Office of
Manufacturing
October 19, 2021 Page 2
cc:       Krystian Czerniecki
FirstName LastName