United States securities and exchange commission logo





                            October 13, 2023

       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. 3 to
Registration Statement on Form F-1
                                                            Filed on September
29, 2023
                                                            File No. 333-270499

       Dear Jim Xu:

            We have reviewed your amended registration statement and have the
following
       comments.

              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 March 17, 2023
letter.

       Amendment No. 3 to Form F-1 filed September 29, 2023

       Dilution, page 59

   1.                                                   Please tell us how your
net tangible book value at June 30, 2023 of $3,286,985 was
                                                        determined. Provide us
with your computation.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Components of Results of Operations, page 65

   2.                                                   We note the second
table on page 65 represents units sold, please explain why you reflect
                                                        the total with a dollar
sign.
       June 30, 2023 Interim Financial Statements
       Notes to Unaudited Interim Condensed Consolidated Financial Statements
 Jim Xu
LOBO EV TECHNOLOGIES LTD
October 13, 2023
Page 2
1. Organization and Principal Activities
Reorganization, page F-6

3.     You disclose that in March 2023, your supplemental agreement with
Jiangsu LOBO
       resulted in additional consideration of $1,437,646 paid related to the
reorganization
       conducted in March 2022. Given that a year has passed since the
reorganization, it is
       unclear why you believe the amounts paid relate to the reorganization
and therefore have
       been reflected retroactively. In this regard, tell us your consideration
of the amounts paid
       as a dividend and tell us how you determined the value of $1,437,646 for
the shares in the
       reorganization. Provide us with the authoritative accounting guidance
you used to support
       your accounting treatment. In addition, please file your supplemental
agreement as part of
       your response.
4.     Your disclosure in the penultimate paragraph on page F-6 states that you
effected a share
       split which increased your authorized and issued shares to 50,000,000.
Shareholders then
       surrendered 44,300,000 shares which were cancelled, leaving 5,700,000
shares issued.
       Please revise to clarify whether you still have 50,000,000 shares
authorized with
       5,700,000 outstanding or whether you no longer have 50,000,000 shares
authorized. Your
       disclose on page F-6 and on the balance sheet should be revised to
separately state the
       number of authorized shares and issued shares.
5.     In a related matter, you disclose that you issued 700,000 shares to
existing shareholders in
       September 2023 on a pro-rata basis. Please revise to retroactively
reflect this stock
       dividend throughout your filing. Refer to SAB Topic 4C. Your earnings
per share should
       also be revised in accordance with ASC 260-10-55-12.
General

6.     We note your added disclosure to page 8 regarding your response to the
CSRC on August
       15, 2023. Please update this disclosure to discuss future filings and
communications
       related to your submission as well as the status of any approval. Also
reconcile those
       additions with your disclosure on the cover page that you are "currently
in the process of
       submitting filing materials to the CSRC."
       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
October 13, 2023 Page 2
cc:       Lawrence Venick
FirstName LastName