SecProbe.io

November 26, 2024
Ara Mahdessian
Chief Executive Officer
ServiceTitan, Inc.
800 N. Brand Blvd
Suite 100
Glendale, CA 91203
Re:ServiceTitan, Inc.
Registration Statement on Form S-1
Filed November 18, 2024
File No. 333-283296
Dear Ara Mahdessian:
            We have reviewed your registration statement and have the following comment.
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form S-1
Prospectus Summary
The Offering, page 16
We note your disclosure here and elsewhere in your prospectus regarding your
directed share program for "eligible customers; friends and family members of [y]our
Co-Founders; and certain other persons." Please expand your disclosure here, and
elsewhere as appropriate, to address how you will determine eligible customers and
other persons, the process that prospective participants will follow to participate in the
program, the manner in which you will communicate with participants and determine
the amount each will receive, when and how you will determine the allocation for the
program, and whether such allocation will change depending on the interest level of
potential participants, as well as any other material features of the program.  Advise us
of the number of potential purchasers who are eligible to receive communications 1.

November 26, 2024
Page 2
about the directed share materials.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Refer to Rule 461 regarding requests for acceleration. Please allow adequate time for
us to review any amendment prior to the requested effective date of the registration
statement.
            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