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                              August 24, 2022

       David Glazer
       Chief Financial Officer
       Palantir Technologies Inc.
       1555 Blake Street; Suite 250
       Denver, CO 80202

                                                        Re: Palantir
Technologies Inc.
                                                            Form 10-K for the
Year Ended December 31, 2021
                                                            Form 10-Q for the
Interim Period Ended June 30, 2022
                                                            File No. 001-39540

       Dear Mr. Glazer:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Form 10-K for the Year Ended December 31, 2021

       4. Investments and Fair Value Measurements
       Investments, page 119

   1.                                                   We note that you
disclose the total value of the commercial contracts associated with your
                                                        investments. In future
filings, please revise to distinguish between the portion of total
                                                        contract value has
already been recognized as revenue and the remaining amount left to be
                                                        recognized as revenue
in future periods.
   2.                                                   So that we may
understand you investment agreements better, please tell us more
                                                        specifically how you
assess the concurrent agreements under the non-monetary guidance
                                                        within ASC 606. Please
also tell us the relationship, if any, between the Investment
                                                        Agreement and the
commercial contract for access to your products and services. For
                                                        example, please clarify
if you are required to hold your investment in the investee for the
                                                        duration of the
commercial contract. Please also clarify if investees are required to
 David Glazer
FirstName  LastNameDavid
Palantir Technologies Inc. Glazer
Comapany
August  24, NamePalantir
            2022         Technologies Inc.
August
Page 2 24, 2022 Page 2
FirstName LastName
         continue paying for products and service if you sell your investment
prior to the end of the
         term of the commercial contract.
Form 10-Q for the Interim Period Ended June 30, 2022

Management's Discussion and Analysis
Russia Invasion of Ukraine, page 23

3.       You disclose on page 23 that in June 2022, your CEO met with the
President of Ukraine
         and other senior officials to discuss opening an office in Ukraine.
Please ensure that
         future filings address your progress, if any, on opening an office in
Ukraine. Your
         disclosures should address the materiality of any operations within
Ukraine and disclose
         any material direct or indirect risks to your business due to having a
presence in Ukraine
         (for example relating to security, internet accessibility or other
infrastructure concerns).
         Please also disclose any steps you have taken or may take to address
those risks.

Results of Operations, page 28

4.       In your August 8, 2022 Form 8-K, you disclosed downward revisions to
expected revenue
         and adjusted income from operations for fiscal 2022. You also
disclosed expectations for
         adjusted income from operations for the third quarter of 2022 that
were approximately
         half of adjusted income from operations for the quarter ended June 30,
2022. Finally, we
         noted that you did not re-affirm your long-term annual revenue
guidance of 30% or more
         through 2025 in that Form 8-K. It does not appear that your MD&A for
the period ended
         June 30, 2022 sufficiently addressed these material changes in
outlook. Please revise your
         future filings to describe, in detail, the nature of any material
disruptions to your outlook
         and business goals. Please also revise to specifically quantify the
impact of these
         disruptions on your results of operations and/or capital resources.
Please refer to Items
         303(a) and (c) of Regulation S-K.
Comparison of the Three and Six Months Ended June 30, 2022 and 2021, page 29

5.       We note that in your Form 8-K dated August 8, 2022, you disclose the
total percentage
         increase in US government revenues year over year, but not the dollar
amount. At the
         February 2022 Morgan Stanley Technology Conference, your Chief
Operating
         Officer expressed the Company's ambition to become the U.S.
government's sixth prime
         contractor and first software prime contractor. This view was
expressed again during the
         August 8, 2022 earnings call. In light of this operational goal and
the fact that you have
         cited delays in U.S. government contract awards as a reason for
material changes to your
         fiscal 2022 guidance, please tell us how you considered providing
greater transparency to
         investors by disclosing total revenue from the U.S. government for
each period presented.
 David Glazer
Palantir Technologies Inc.
August 24, 2022
Page 3

       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.

        You may contact Lisa Etheredge, Senior Staff Accountant, at (202)
551-3424 or Robert
S. Littlepage, Accounting Branch Chief, at (202) 551-3361 with any questions.



FirstName LastNameDavid Glazer                            Sincerely,
Comapany NamePalantir Technologies Inc.
                                                          Division of
Corporation Finance
August 24, 2022 Page 3                                    Office of Technology
FirstName LastName