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United States securities and exchange commission logo
November 29, 2023
Qingfeng Feng
Chief Executive Officer
Lotus Technology Inc.
No. 800 Century Avenue
Pudong District, Shanghai
People's Republic of China
Re: Lotus Technology
Inc.
Amendment No. 1 to
Registration Statement on Form F-4
Filed November 15,
2023
File No. 333-275001
Dear Qingfeng Feng:
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.
Amendment No. 1 to Registration Statement on Form F-4 filed November 15,
2023
Recent Development of Lotus Tech, page 39
1. Please revise the
disclosure in this section to remove any implication that investors should
not rely on the
information presented. If you choose to disclose preliminary results, you
should be able to
assert that the actual results are not expected to differ materially from
that reflected in the
preliminary results. Additionally, revise your disclosures to
prominently label as
preliminary at the beginning of your discussion.
Unaudited Pro Forma Condensed Combined Financial Information, page 326
2. Please revise you
reference that the LCAA's unaudited information as of and for the six
months ended June 30,
2023 are included elsewhere in the proxy statement/prospectus.
Qingfeng Feng
FirstName LastNameQingfeng Feng
Lotus Technology Inc.
Comapany 29,
November NameLotus
2023 Technology Inc.
November
Page 2 29, 2023 Page 2
FirstName LastName
Please contact Kevin Stertzel at 202-551-3723 or Melissa Gilmore at
202-551-3777 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Thomas Jones at 202-551-3602 or Erin Purnell at 202-551-3454 with any
other
questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing
cc: Shu Du, Esq.