SecProbe.io

November 4, 2024
Ara Mahdessian
Chief Executive Officer
ServiceTitan, Inc.
800 N. Brand Blvd
Suite 100
Glendale, CA 91203
Re:ServiceTitan, Inc.
Amendment No. 4 to Draft Registration Statement on Form S-1
Submitted October 22, 2024
CIK No. 0001638826
Dear Ara Mahdessian:
            We have reviewed your amended 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.
Amendment No. 4 to Draft Registration Statement on Form S-1
Prospectus Summary, page 1
1.We note your revised disclosure that your net dollar retention rate has declined
slightly over the last ten fiscal quarters. Given your prominent disclosure throughout
the filing that your net dollar retention rate and gross dollar retention rate is evidence
of your ability to retain and expand customers, please provide balanced disclosure by
providing appropriate context regarding the decrease in your net retention rate and/or
gross retention rate. Disclose the amount of the decrease in rates over the period.
Clarify whether management uses the annual net dollar retention rate and gross dollar
retention rate to evaluate the company's business.

November 4, 2024
Page 2
Notes to Condensed Consolidated Financial Statements
14. Subsequent Events, page F-73
2.You disclose the following:

•Between July 31, 2024 and September 9, 2024, the Company granted 245,653
RSUs vesting over four years and subject to service-only conditions.
•Between September 10, 2024 and October 21, 2024, the Company granted 51,674
RSUs vesting over four years and subject to service-only conditions.
•Additionally, in October 2024, the Company granted each of Ara Mahdessian and
Vahe Kuzoyan an award of 3,241,544 performance-based RSUs.

Please revise your subsequent events disclosure beginning on page F-74 to disclose
the expected financial impact of the awards (i.e. unrecognized compensation expense)
pursuant to ASC 855-10-50-2(b). In addition, please tell us the grant date fair value of
the shares of common stock used to determine the amount of compensation expense
attributable to each of these grants. Please reconcile and explain the differences
between the fair values of a share of common stock determined on each grant date
including the difference between the most recent grant date fair value and the
midpoint of your offering range.
General
3.Please provide balanced disclosure in the graphics in the forepart of the registration
statement.  Please also disclose the net loss for each period that you discuss revenue
and revenue growth.
            Please contact Amanda Kim at 202-551-3241 or Stephen Krikorian at 202-551-3488
if you have questions regarding comments on the financial statements and related
matters. Please contact Marion Graham at 202-551-6521 or Jan Woo at 202-551-3453 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:Phillip Stoup