United States securities and exchange commission logo
August 30, 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. 2 to
Registration Statement on Form F-3
Filed August 5,
2022
File No. 333-263315
Dear Mr. Ye:
We have reviewed your amended registration statement and have the
following
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 July
19, 2022 letter.
Amendment No. 2 to Registration Statement on Form F-3 filed August 5,
2022
General
1. Please provide a
factual update on your cover page, prospectus summary, and risk factors
to disclose the
agreement reached between the PCAOB and the CSRC on August 26,
2022.
Cover Page
2. We note your response
to prior comment 1. Please continue to revise your disclosure to
refrain from using such
terms as "we" or "our" when describing activities or functions of
Jianhui Ye
EZGO Technologies Ltd.
August 30, 2022
Page 2
the VIE. For example, we note the caption of the risk factor on page 20
that the "PRC
government exerts substantial influence over the manner in which we
conduct our
business activities."
Conventions that apply to this prospectus, page ii
3. We note your response to prior comment 3. However, comment 3 did not
refer to the
qualifications of counsel. As previously requested, revise the
definition of the PRC or
China to include Hong Kong and Macau and revise the disclosure
throughout your
amendment accordingly.
Enforceability of Civil Liabilities, page 45
4. We note your response to prior comment 6. Please expand the disclosure
to identify that a
majority of your current directors and officers are nationals and
residents of the PRC.
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
August 30, 2022 Page 2
cc: Richard I. Anslow, Esq.
FirstName LastName