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                              August 17, 2023

       Oguz Alper   ktem
       Chief Executive Officer
       Marti Technologies, Inc.
       Buyukdere Cd. No:237
       Maslak, 34485
       Sariyer/Istanbul, T  rkiye

                                                        Re: Marti Technologies,
Inc.
                                                            Registration
Statement on Form F-1
                                                            Filed July 31, 2023
                                                            File No. 333-273543

       Dear Oguz Alper   ktem:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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.

       Registration Statement on Form F-1 filed July 31, 2023

       Cover Page

   1.                                                   Please revise your
disclosure here and throughout the prospectus to disclose the price
                                                        that each selling
securityholder paid for the ordinary shares and warrants (both Public
                                                        Warrants and Private
Placement Warrants, respectively) being registered for resale as
                                                        outlined on the
prospectus cover page. Highlight any differences in the current trading
                                                        price, the prices that
the Sponsor, private placement investors and other selling
                                                        securityholders
acquired their ordinary shares and warrants, and the price that the public
                                                        securityholders
acquired their ordinary shares and warrants. Disclose that while the
                                                        Sponsor, private
placement investors and other selling securityholders may experience a
                                                        positive rate of return
based on the current trading price, the public securityholders may
 Oguz Alper   ktem
Marti Technologies, Inc.
August 17, 2023
Page 2
         not experience a similar rate of return on the securities they
purchased due to differences
         in the purchase prices and the current trading price. Please also
disclose the potential
         profit the selling securityholders will earn based on the current
trading price. Lastly,
         please include appropriate risk factor disclosure.
2.       We note your disclosure here and in the Use of Proceeds section
discussing the likelihood
         that warrant holders will not exercise their warrants if the warrants
are out of the money.
         Provide similar disclosure in the prospectus summary, risk factors and
MD&A sections
         and disclose that cash proceeds associated with the exercise of the
warrants are dependent
         on stock price. As applicable, please describe the impact on your
liquidity and update
         your discussion on the ability of your company to fund your operations
on a prospective
         basis with your current cash on hand should warrant holders not
exercise their warrants.
         We note your disclosure on page 86 regarding existing cash flows, cash
used by operating
         activities and cash provided by financing activities. If you are
likely to have to seek
         additional capital, discuss the effects of this offering on the
company's ability to raise
         additional capital.
3.       We note your disclosure that you will receive proceeds from the
exercise of the Public
         Warrants and Private Placement Warrants for cash, but not from the
sale of ordinary
         shares issuable upon such exercise. Please disclose here and in the
Prospectus Summary
         and Use of Proceeds sections as well as in your discussion of
liquidity and capital
         resources the aggregate proceeds you may receive assuming the exercise
of all warrants
         by securityholders.
4.       Please revise your disclosure where appropriate to disclose the amount
of shares being
         registered as a percentage of your total public float. Additionally,
highlight the significant
         negative impact sales of shares on this registration statement could
have on the public
         trading price of your ordinary shares.
Risk Factors, page 14

5.     Include an additional risk factor highlighting the negative pressure
potential sales of
       shares pursuant to this registration statement could have on the public
trading price of
       your ordinary shares. To illustrate this risk, disclose the purchase
price of the securities
       being registered for resale and the percentage that these shares
currently represent of the
       total number of shares outstanding. Also disclose that even though the
current trading
FirstName LastNameOguz Alper   ktem
       price is significantly below the SPAC IPO price, the private investors
have an incentive to
Comapany    NameMarti
       sell because  theyTechnologies,
                          will still profitInc.
                                            on sales because of the lower price
that they purchased
       their shares than
August 17, 2023 Page 2   the public   investors.
FirstName LastName
 Oguz Alper   ktem
FirstName LastNameOguz
Marti Technologies, Inc. Alper   ktem
Comapany
August 17, NameMarti
           2023        Technologies, Inc.
August
Page 3 17, 2023 Page 3
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.

       Please contact Kate Beukenkamp at 202-551-3861 or Donald Field at
202-551-3680 with
any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Trade &
Services
cc:      Scott Westhoff