September 25, 2024 Qingfeng Feng Chief Executive Officer Lotus Technology Inc. No. 800 Century Avenue Pudong District, Shanghai, People s Republic of China Re: Lotus Technology Inc. Registration Statement on Form F-1 Filed September 19, 2024 File No. 333-282217 Dear Qingfeng Feng: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Eranga Dias at 202-551-8107 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing