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                                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.
 Jim Xu
FirstName
LOBO EV LastNameJim     Xu LTD
          TECHNOLOGIES
Comapany21,
December  NameLOBO
              2022     EV TECHNOLOGIES LTD
December
Page 2    21, 2022 Page 2
FirstName LastName
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
 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,
FirstName LastNameJim Xu
                                                          Division of
Corporation Finance
Comapany NameLOBO EV TECHNOLOGIES LTD
                                                          Office of
Manufacturing
December 21, 2022 Page 3
cc:       Lawrence Venick
FirstName LastName