United States securities and exchange commission logo





                              June 1, 2023

       Kemal Kaya
       Chief Executive Officer
       Galata Acquisition Corp.
       2001 S Street NW, Suite 320
       Washington, DC 20009

                                                        Re: Galata Acquisition
Corp.
                                                            Amendment No. 2 to
Registration Statement on Form F-4
                                                            Filed May 19, 2023
                                                            File No. 333-269067

       Dear Kemal Kaya:

             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 March
27, 2023 letter.

       Amendment No. 2 to Registration Statement on Form F-4 Filed May 19, 2023

       Cover Page

   1.                                                   We note that on April
28, 2023, Galata Merger Sub and Marti amended the lock-up
                                                        restrictions pursuant
to the terms of the BCA Amendment to apply only to Class A
                                                        Ordinary Shares, Marti
Options, and other equity awards held by and/or issued to
                                                        employees of Marti.
Please revise your disclosure here and elsewhere throughout your
                                                        prospectus to identify
the investors and the investments that will no longer be subject to
                                                        lock-ups. In doing so,
please disclose their relationships with Galata and Marti.

                                                        We note that your
disclosure reflects that the Second PIPE Amendment, for example,
                                                        removed the lock-up
restrictions applicable to PIPE Investors and under "Amendments to
 Kemal Kaya
Galata Acquisition Corp.
June 1, 2023
Page 2
      Letter Agreements" on page 250 you state that Galata, the Sponsor and
Insiders (defined
      as Galata Board and Galata's management team) agreed to remove the
applicable IPO
      Lock-Up Restrictions from the Letter Agreements. Additionally, we note
your revisions
      on page 237 under "Lockup Period" to clarify that only any "employee of,
or service
      provider to" Marti are subject to restrictions on proposed transfer of
Lockup Securities.
Marti Management's Discussion and Analysis of Financial Condition and Results
of Operations
Year Ended December 31, 2022 Compared to Year Ended December 31, 2021
Results of Operations, page 250

2.    Your financial income increased to $2.6 million from $0.2 million during
the year ended
      December 31, 2022. Additionally, your financial expense decreased to $1.9
million from
      $4.7 million during the year ended December 31, 2022. Please explain the
reasons for the
      changes year over year.
       You may contact Nasreen Mohammed at 202-551-3773 or Lyn Shenk at
202-551-3380 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Kate Beukenkamp at 202-551-3861 or Dietrich King at 202-551-8071 with
any other
questions.



                                                           Sincerely,
FirstName LastNameKemal Kaya
                                                           Division of
Corporation Finance
Comapany NameGalata Acquisition Corp.
                                                           Office of Trade &
Services
June 1, 2023 Page 2
cc:       Michael E. Brandt
FirstName LastName