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
 Jim Xu
FirstName
LOBO EV LastNameJim     Xu LTD
           TECHNOLOGIES
Comapany
October 26,NameLOBO
            2022       EV TECHNOLOGIES LTD
October
Page 2 26, 2022 Page 2
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         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,
 Jim Xu
FirstName
LOBO EV LastNameJim     Xu LTD
           TECHNOLOGIES
Comapany
October 26,NameLOBO
            2022       EV TECHNOLOGIES LTD
October
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             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
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FirstName
LOBO EV LastNameJim     Xu LTD
           TECHNOLOGIES
Comapany
October 26,NameLOBO
            2022       EV TECHNOLOGIES LTD
October
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         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,
 Jim Xu
LOBO EV TECHNOLOGIES LTD
October 26, 2022
Page 5
FirstName LastNameJim Xu
                                        Division of Corporation Finance
Comapany NameLOBO EV TECHNOLOGIES LTD
                                        Office of Manufacturing
October 26, 2022 Page 5
cc:       Lawrence Venick
FirstName LastName