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United States securities and exchange commission logo
December 15, 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. 2 to
Registration Statement on Form F-4
Filed December 5,
2023
File No. 333-275001
Dear Qingfeng Feng:
We have reviewed your
amended registration statement and have the following comment.
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. 2 to Registration Statement on Form F-4 filed December 5,
2023
Summary of the Proxy Statement/Prospectus
Permissions Required from the PRC Authorities for Lotus Tech's
Operations, page 35
1. If you will be
requesting effectiveness of your Form F-4 registration statement before
completing the CSRC
process, please confirm in writing that you will notify us promptly
of any changes to your
disclosure regarding or requested by the CSRC.
Qingfeng Feng
FirstName LastNameQingfeng Feng
Lotus Technology Inc.
Comapany15,
December NameLotus
2023 Technology Inc.
December
Page 2 15, 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.