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                             December 4, 2023

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

                                                        Re: Marti Technologies,
Inc.
                                                            SC TO-I filed
November 21, 2023
                                                            File No. 005-92684

       Dear Oguz Alper   ktem:

              We have reviewed your filing 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 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.

       Schedule TO-I filed November 21, 2023; Offer to Purchase

       General

   1.                                                   Please ensure on future
filings that the EDGAR tag "SC 13E-3/A" is associated with the
                                                        filing, in addition to
the EDGAR tag "SC TO-I/A."
   2.                                                   We note disclosure in
multiple places in the Offer to Purchase and the offer's ancillary
                                                        documents that
indicates that the consent of an additional 34% of the outstanding Public
                                                        Warrants is needed to
approve the Warrant Amendment. However, when combined with
                                                        the existing 26% who
have agreed to approve, the addition of that 34% would lead to an
                                                        approximate 60%
aggregate approval, well in excess of the mere majority approval that is
                                                        otherwise stated as
being the relevant threshold. Please revise, or advise.
   3.                                                   We note the following
disclosure, which appears in three separate places in the Offer to
                                                        Purchase: "The
foregoing conditions are solely for our benefit, and we may assert one or
                                                        more of the conditions
regardless of the circumstances giving rise to any such conditions."
 Oguz Alper   ktem
Marti Technologies, Inc.
December 4, 2023
Page 2
         All offer conditions must be objective and outside the control of the
offeror in order to
         avoid illusory offer concerns under Regulation 14E. Please revise the
language relating to
         the circumstances that may "trigger" an offer condition to avoid the
implication that they
         may be within the Company's control. See Question 101.02 of the
Division of Corporation
         Finance's "Tender Offer Rules and Schedules" Compliance and Disclosure
Interpretations.
Section 7. Information Concerning Marti Technologies, Inc., page 26

4.       In circumstances where the registrant elects to incorporate by
reference the information
         required by Item 1010(a) and (b) of Regulation M-A, all of the
summarized financial
         information required by Item 1010(c) must be disclosed in the document
furnished to
         security holders. See Instruction 1 to Item 13 of Schedule 13E-3. In
addition, please refer
         to telephone interpretation I.H.7 in the July 2001 supplement to our
 Manual of Publicly
         Available Telephone Interpretations    that is available on the
Commission   s website at
         http://www.sec.gov for guidance on complying with a similar
instruction in the context of
         a tender offer. Please revise the disclosure to include the
information required by Item
         1010(c)(1), (2) and (3).
        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

         Please direct any questions to David Plattner at 202-551-8094.



FirstName LastNameOguz Alper   ktem                            Sincerely,
Comapany NameMarti Technologies, Inc.
                                                              Division of
Corporation Finance
December 4, 2023 Page 2                                       Office of Mergers
and Acquisitions
FirstName LastName