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 May 13, 2025

Daniel Ramot
Chief Executive Officer
Via Transportation, Inc.
114 5 th Ave, 17 th Floor
New York, NY 10011

 Re: Via Transportation, Inc.
 Draft Registration Statement on Form S-1
 Submitted April 15, 2025
 CIK No. 0001603015
Dear Daniel Ramot:

 We have reviewed your draft registration statement and have the
following comments.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-1
Cover Page

1. You state that the Chief Executive Officer and Chairman, Daniel Ramot,
will have
 control over most matters that require approval by your stockholders,
including the
 election of directors and approval of significant corporate
transactions. Here and
 elsewhere as appropriate, if true, please disclose that you will be
considered a
 "controlled company" following this offering under NYSE listing
standards, if true. If
 this is the case, please also disclose whether you intend to rely on the
exemptions to
 corporate governance requirements as a controlled company.
 May 13, 2025
Page 2
Prospectus Summary, page 1

2. We note that you attribute statements to "Third Party Market Data,"
including
 references to the report you commissioned from BCG. Please revise to
state the
 specific source of each statement.
Summary Consolidated Financial and Operating Information, page 19

3. Please provide a reconciliation of the weighted average number of shares
of common
 stock used in computing net loss per share to the weighted average
number of shares
 of common stock used in computing pro forma net loss per share, once
amounts are
 known. Describe each transaction and the number of shares included.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Factors Affecting Our Performance
Revenue Retention, page 82

4. We note your disclosure of dollar-based gross revenue retention for
government
 customers. Tell us how you considered also disclosing dollar-based gross
revenue
 retention for all customers.
Results of Operations
Comparison of the Years Ended December 31, 2023 and 2024
Revenue, page 87

5. Tell us how you considered disclosing the increase in Platform revenue
attributable to
 having a full year of CityMapper results in your financial statements
for the year
 ended December 31, 2024.
Certain Relationship and Related Party Transactions, page 143

6. Please disclose the parties to the Investors' Rights Agreement. We note
that you intend
 to terminate the rights under the current agreement and enter into a new
agreement
 that provides similar registration rights.
Consolidated Financial Statements
Notes to Consolidated Financial Statements
2. Significant Accounting Policies
Revenue Recognition
Revenue Arrangements, page F-15

7. Clarify how the transaction price is allocated among your subscription
services and
 professional services when these services are included in the same
contract with
 customers. Refer to ASC 606-10-32-31 through 32-35. Further, tell us
what
 consideration you gave to separately disclosing professional services,
if material.
Remaining Performance Obligations, page F-16

8. Please revise your disclosures to clarify how the anticipated number of
driver hours
 and service hours is determined in your estimation of variable revenue.
That is, clarify
 whether these estimates are based on historical volumes used by
customers or some
 other manner, and clarify what you mean by stipulated in the
contract. Refer to ASC
 606-10-32-8 and 32-9.
 May 13, 2025
Page 3

15. Stockholders' Deficit, page F-32

9. When your preliminary IPO price is known, please provide us with a
breakdown of all
 equity awards granted from six month before the date of this letter and
leading up to
 the preliminary pricing of your IPO. This breakdown should list grants
in chorological
 order including the fair value of the underlying common stock used to
value such
 awards as determined by your board of directors. Please reconcile and
explain the
 differences between the fair values of the underlying equity interest
determined on
 each grant date, including the difference between the most recent grant
date fair value
 and the midpoint of your offering range. In addition, your disclosure
should fully
 describe the assumptions utilized at the IPO valuation date that are
significantly
 different than those used in the most recent valuation.
General

10. Please supplementally provide us with copies of all written
communications, as
 defined in Rule 405 under the Securities Act, that you, or anyone
authorized to do so
 on your behalf, present to potential investors in reliance on Section
5(d) of the
 Securities Act, whether or not they retain copies of the communications.
11. Many of your tables and graphics include print that is not legible. For
example, your
 graphic on page 116 contains text that is too small to be legible.
Please revise
 your graphics throughout your prospectus as applicable to ensure that
the text is
 legible.
 Please contact Laura Veator at 202-551-3716 or Stephen Krikorian at
202-551-3488 if
you have questions regarding comments on the financial statements and related
matters. Please contact Mariam Mansaray at 202-551-6356 or Jan Woo at
202-551-3453 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Ryan J. Dzierniejko
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