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                             July 18, 2023

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

                                                        Re: SURF AIR MOBILITY
INC.
                                                            Amendment No. 2 to
Registration Statement on Forms S-1 and S-4
                                                            Filed July 3, 2023
                                                            Amendment No. 3 to
Registration Statement on Forms S-1 and S-4
                                                            Filed July 13, 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.

       Amendment No. 3 to Registration Statement on Forms S-1 and S-4

       Related Agreements and Transactions
       Management Incentive Plan , page 155

   1.                                                   We note your disclosure
that, as contemplated by the Southern Acquisition Agreement,
                                                        SAM adopted an
incentive plan that provides an opportunity for selected employees and
                                                        other service providers
of Southern and its subsidiaries to earn bonuses if Southern's
                                                        revenue (as specified
in the plan) over the 15-month and 27-month periods following the
                                                        closing exceeds
threshold levels set forth in the plan. Please revise to disclose the
                                                        applicable revenue
thresholds and file a copy of this incentive plan as an exhibit to your
                                                        registration statement.
 Sudhin Shahani
SURF AIR MOBILITY INC.
July 18, 2023
Page 2
Principal and Registered Stockholders, page S-8

2.    We note your response to our prior comment 2. Because the public listing
is conditioned
      on the consummation of the Southern Airways acquisition, the GEM resale
transactions
      effectively contain an additional condition beyond the filing or
effectiveness of the
      registration statement. Please revise the registration statement to
remove the resale
      transactions.
        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
July 18, 2023 Page 2
cc:       Jeeho Lee, Esq.
FirstName LastName