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                               June 27, 2023

       Sudhin Shahani
       Chief Executive Officer
       SURF AIR MOBILITY INC.
       12111 S. Crenshaw Blvd.
       Hawthorne, CA 90250

                                                        Re: SURF AIR MOBILITY
INC.
                                                            Amendment No. 1 to
Registration Statement on Forms S-1 and S-4
                                                            Filed June 22, 2023
                                                            File No. 333-272403

       Dear Sudhin Shahani:

             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 June
16, 2023 letter.

       Amendment No.1 to Registration Statement on Forms S-1 and S-4

       Background of the Southern Acquisition, page 84

   1.                                                   We note your revised
disclosure in response to prior comment 1 and reissue the
                                                        comment. Please revise
to quantify Southern's revenue in 2019. Also quantify
                                                        the revenue growth
reflected in Southern's projected 2020 revenue and describe related
                                                        material assumptions.
       Principal and Registered Stockholders, page S-9

   2.                                                   Footnote 8 to the
Principal and Registered Stockholders table indicates that this
                                                        registration statement
is intended to cover the resale of of shares that have not yet been
                                                        issued and will not be
issued until the direct listing occurs or thereafter, including
 Sudhin Shahani
SURF AIR MOBILITY INC.
June 27, 2023
Page 2
      1,300,000 shares to be issued to GEM in connection with the Initial GEM
Issuance under
      the Share Subscription Facility, as amended, and 1,000,000 shares to be
issued in
      connection with the GEM Purchase under the GEM Purchase Agreement. For
each
      issuance, please provide a detailed legal analysis explaining why you
believe it is
      appropriate to register the resale of those shares pursuant to this
registration statement. In
      formulating your response, please consider Questions 139.06 and 139.13 of
our Securities
      Act Sections Compliance and Disclosure Interpretations.
        You may contact Yolanda Guobadia, Staff Accountant, at 202-551-3562 or
Robert
Babula, Staff Accountant, at 202-551-3339 if you have questions regarding
comments on the
financial statements and related matters. Please contact Irene
Barberena-Meissner, Staff
Attorney, at 202-551-6548 or Mitchell Austin, Staff Attorney, at 202-551-3574
with any other
questions.



                                                             Sincerely,
FirstName LastNameSudhin Shahani
                                                             Division of
Corporation Finance
Comapany NameSURF AIR MOBILITY INC.
                                                             Office of Energy &
Transportation
June 27, 2023 Page 2
cc:       Jeeho Lee, Esq.
FirstName LastName