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                                                            September 3, 2024

Wolfgang Breme
Chief Financial Officer
Ads-Tec Energy Public Limited Company
10 Earlsfort Terrace
Dublin 2, D02 T380, Ireland

       Re: Ads-Tec Energy Public Limited Company
           Form 20-F for the Fiscal Year Ended December 31, 2023
           Filed April 30, 2024
           Form 6-K Furnished May 14, 2024
           File No. 001-41188
Dear Wolfgang Breme:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 6-K Furnished May 14, 2024
Exhibit 99.1, page 1

1.     We note that you present a non-IFRS financial measure, adjusted EBITDA,
without
       presenting the most directly comparable IFRS measure. Please revise your
disclosures
       accordingly to present the most directly comparable IFRS measure and
include a
       reconciliation pursuant to Item 100(a)(1)-(2) of Regulation G.
2.     We note that your reconciliation of proforma adjusted EBITDA to net loss
in the February
       2024 investor presentation includes adjustments related to provision for
onerous contracts,
       write-down on inventories, and reclassification of R&D funding. As these
costs appear to
       be normal recurring operating expenses, please remove these adjustments.
Refer to
       Question 100.01 of the SEC Staff   s C&DI on Non-GAAP Financial
Measures.
3.     We note your disclosure that you anticipate 2024 full-year revenues to
exceed EUR 200
       million and positive EBITDA for 2024. Tell us your consideration for
providing similar
       context for profitability on an IFRS-IASB basis. If the GAAP financial
measure is not
 September 3, 2024
Page 2

       accessible on a forward-looking basis, you are required to disclose that
fact and provide
       reconciling information that is available without an unreasonable
effort. Please revise you
       disclosure in future press releases to comply with Rule 100(a) of
Regulation G.
Form 20-F for the Fiscal Year Ended December 31, 2023
Item 5. Operating and Financial Review and Prospects
Results of Operations, page 48

4.     Where you identify intermediate causes of changes in your operating
results, please also
       describe in sufficient detail the reasons underlying the intermediate
causes in future
       filings. As an example, you disclose on page 49 that total revenue
increased from the year
       ended December 31, 2022 to December 31, 2023 primarily due to the
extension of your
       business, and the increase relates to higher sales of the product
ChargePost in Europe;
       however, you do not explain in reasonable detail the reasons driving the
increase in sales
       of the product. Refer to Item 5.A.1 of Form 20-F.
Notes to consolidated financial statements
4.2.5. Inventories, page F-42

5.     Please tell us and expand your disclosures in future filings to provide
additional insight
       for the increase in inventory write-downs in 2023. Additionally, expand
your critical
       accounting policy disclosures to identify the material assumptions you
used in
       determining the inventory write-downs, including more details of how you
develop
       certain assumptions, such as forecasted usage and sales. Refer to Item
5.E of Form 20-F.
6. Related party transactions, page F-64

6.     We note your disclosures of related party transactions on page F-64.
Please revise future
       filings to separately quantify your related party transactions on the
face of your financial
       statements. Refer to Rule 4-08(k) of Regulation S-X.
       In closing, 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 Stephany Yang at 202-551-3167 or Melissa Gilmore at
202-551-3777 with
any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Manufacturing
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