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                             November 9, 2020

       Dara Khosrowshahi
       Chief Executive Officer
       Uber Technologies, Inc
       1455 Market Street, 4th Floor
       San Francisco, California 94103

                                                        Re: Uber Technologies,
Inc
                                                            Amendment No. 2 to
Registration Statement on Form S-4
                                                            Filed October 26,
2020
                                                            File No. 333-242307

       Dear Mr. Khosrowshahi:

              We have reviewed your 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.

       Amendment No. 2 to Registration Statement on Form S-4 filed October 26,
2020

       Background of the Transaction, page 63

   1.                                                   We note your response
to prior comment 7 and your analysis as to why you believe the
                                                        disclosure is not
necessary. However, we are unable to agree with your conclusion that
                                                        the valuation analyses
would be of limited value to stockholders. Please disclose the
                                                        valuation analyses
(including transaction price multiple and discounted cash flow
                                                        analysis), and
potential synergies discussed by the board at the July 1, 2020 meeting or
                                                        provide further
analysis, referring to staff guidance where applicable, to explain why you
                                                        believe the disclosure
is not required.
 Dara Khosrowshahi
FirstName LastNameDara
Uber Technologies, Inc Khosrowshahi
Comapany 9,
November  NameUber
             2020     Technologies, Inc
November
Page 2    9, 2020 Page 2
FirstName LastName
        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.

      You may contact Keira Nakada at (202) 551-3659 if you have questions
regarding
comments on the financial statements and related matters. Please contact Daniel
Morris at (202)
551-3314 or Erin Jaskot at (202) 551-3442 with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services
cc:      Andrew Nussbaum, Esq.