United States securities and exchange commission logo
September 21, 2022
Jianhui Ye
Chief Executive Officer
EZGO Technologies Ltd.
Building #A, Floor 2
Changzhou Institute of Dalian University of Technology
Wujin District, Changzhou City
Jiangsu, China 213164
Re: EZGO Technologies
Ltd.
Amendment No. 3 to
Registration Statement on Form F-3
Filed September 8,
2022
File No. 333-263315
Dear Mr. Ye:
We have limited our review of your amended registration statement
to those issues we
have addressed in our comments. In some of our comments, we may ask you
to provide us with
information so we may better understand your disclosure.
Please respond to this letter by amending your registration
statement and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.
Unless we note
otherwise, our references to prior comments are to comments in our
August 30, 2022 letter.
Amendment No. 3 to Registration Statement on Form F-3 filed September 8,
2022
Conventions that apply to this Prospectus, page ii
1. We note your response
to prior comment 3 and we reissue the comment. Regarding
the revised definition
of China or PRC appears to include "Hong Kong, Macau and
Taiwan, unless the
context otherwise indicates" and "When used in the the case of laws
and regulations of
China or the PRC, it refers to only such laws and regulations of
mainland China," revise
your disclosure to include a definition of China or PRC that does
not include such
exclusions and is not limited to only such laws and regulations of
mainland China. Also,
remove from the definition the reference to "unless the context
Jianhui Ye
EZGO Technologies Ltd.
September 21, 2022
Page 2
otherwise indicates."
Risk Factors, page 18
2. Please discuss whether recent increased cases of COVID-19 and/or
shutdowns related to
additional or increased outbreaks have had a material impact on your
operations, supply
chain, liquidity or capital resources. In this regard, we note the
information about COVID-
19 in your press release filed as exhibit 99.1 to your Form 6-K filed
August 18, 2022.
3. We note the references to inflation on page 24. Please update this risk
factor if recent
inflationary pressures have materially impacted your operations. In this
regard, identify
the types of inflationary pressures you are facing and how your business
has been
affected.
Please contact Thomas Jones at 202-551-3602 or Erin Purnell at
202-551-3454 with any
questions.
Sincerely,
FirstName LastNameJianhui Ye
Division of
Corporation Finance
Comapany NameEZGO Technologies Ltd.
Office of
Manufacturing
September 21, 2022 Page 2
cc: Richard I. Anslow, Esq.
FirstName LastName