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March 14, 2025
Qingfeng Feng
Chief Executive Officer
Lotus Technology Inc.
No. 800 Century Avenue
Pudong District, Shanghai
People s Republic of China
Re: Lotus Technology Inc.
Post Effective Amendment No. 1 to Registration Statement on Form F-3
Filed March 4, 2025
File No. 333-282217
Dear Qingfeng Feng:
We have conducted a limited review of your registration statement and
have the
following comment(s).
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.
Form F-3
General
1. Please revise to provide updated financial statements and related
disclosures as
required by Item 5(b)(2) of Form F-3 and Item 8.A.5 of Form 20-F.
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
March 14, 2025
Page 2
Please contact Kristin Baldwin at 202-551-7172 or Jennifer Angelini at
202-551-3047
with any other questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing