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 June 3, 2025

Daniel S. O Toole
Chief Executive Officer
Arrive AI Inc.
12175 Visionary Way
Fishers, IN 46038

 Re: Arrive AI Inc.
 Draft Registration Statement on Form S-1
 Submitted May 14, 2025
 CIK No. 0001818274
Dear Daniel S. O Toole:

 We have conducted a limited review of your draft registration statement
and have the
following comment(s).

 Please respond to this letter by providing any requested information
and by publicly
filing your registration statement and non-public draft submission 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 filed
registration statement, we may have additional comments.

Draft Registration Statement on Form S-1
Cover Page

1. Please provide a recent Nasdaq sale price. In addition, revise the third
sentence to
 clarify that such sale prices are a result of private transactions, as
opposed to public
 sales.
2. We note that you refer to a resale of up to 8,125,779 shares by "the
selling
 stockholder." Please amend the cover page, and elsewhere, to reflect
that there are
 multiple selling stockholders. In addition, please amend the cover page
to highlight
 that 8,000,000 of the 8,125,779 shares are being registered for a single
selling
 stockholder, Streeterville Capital, LLC, pursuant to an equity line
agreement.
3. Please revise the prospectus cover page and page 62 to identify
Streeterville Capital
 LLC as an underwriter. For guidance, refer to Securities Act Sections
Compliance and
 Disclosure Interpretation 139.13.
 June 3, 2025
Page 2

Table of Contents, page i

4. Please include a line item for the section titled "Selling Stockholders"
starting on page
 58. Refer to Item 502(a) of Regulation S-K.
Risk Factors, page 5

5. Please disclose, in a new or existing risk factor, if true, the
possibility that the
 company may not have access to the full amount available to it pursuant
to the
 Streeterville Purchase Agreement, that Streeterville may engage in
short-selling
 activities, and, if so, how any sales activities after announcement of a
put may
 negatively affect the company s share price. Also disclose any short
selling of the
 company's securities or other hedging activities that Streeterville has
or may engage
 in.
Risks Related to our Business and Operations - General Risks
Raising additional capital may cause dilution to our existing stockholders or
restrict our
commercial operations., page 8

6. Please revise your risk factor disclosure, or add new risk factor
disclosure, to state that
 this offering will cause dilution and has the potential to cause price
drops for existing
 holders of your securities. Also describe the dilutive effect of the
pricing mechanism
 under the Streeterville Purchase Agreement on the company's share price,
so that
 investors understand the dilutive impact of future puts, as well.
Business
Intellectual Property
Securities Purchase Agreement between Arrive AI Inc. and Streeterville Capital
LLC, page
43

7. We note your disclosure that the Company agrees to restrict its
executive officers
 from selling their shares until the later of 90 days from the agreement
date "or 45 days
 after the effective date of this registration statement." We note that
your initial
 offering registration statement had largely identical language. Please
revise to clarify
 if the 45 day count begins from the effective date of your initial
registration statement,
 or this current registration statement.
Potential Partnership collaboration between Arrive AI Inc., formerly Arrive
Technology Inc.,
formerly Dronedek Corporation, and Hush..., page 43

8. On page 43 you disclose that you were due to begin negotiations for a
"potential
 partnership" with Hush Aerospace following the "completion of this
offering." As it
 appears this disclosure is unchanged from your initial offering
registration statement,
 please update to reflect the current state of negotiations with Hush
Aerospace. Please
 ensure that any other references in the filing to "this offering" refer
to the current
 secondary offering and not your initial direct listing.
Principal and Registered Stockholders, page 56

9. Please revise the statement that the table contains "the number of
shares of our
 common stock held by and registered for resale by means of this
prospectus for the
 June 3, 2025
Page 3

 selling stockholders," as this prospectus does not cover the shares
identified in the
 table on page 57. Also revise the following statement, as it does not
appear to be
 accurate with respect to the current prospectus: "All outstanding shares
as of the date
 of this prospectus represent one hundred percent (100%) of the company
s currently
 issued and outstanding common stock, all of such outstanding shares as
of the date of
 this prospectus may be freely sold upon the effective date of this
registration
 statement." Further revise the tables in this and the following section
to state the
 number of shares currently issued and outstanding.
Selling Stockholders, page 58

10. You disclose on page 59 that the second column of the chart on the same
page "lists
 the number of shares of common stock beneficially owned by each selling
 stockholder, based on its ownership of Resale Shares as of the date of
this
 prospectus." This description is inconsistent with the second column
heading of
 "Number of Shares of Common Stock Beneficially Owned Prior to this
Offering,"
 which appears to include both Resale Shares and shares that were
registered under the
 direct listing. Please revise for consistency and accuracy.
11. Please revise your description of the Streeterville Purchase Agreement
to disclose the
 material terms of the agreement with Streeterville including without
limitation: (i) the
 term of the agreement, and (ii) the full discounted price (or formula
for determining it)
 at which Streeterville will receive the shares. For guidance, refer to
Securities Act
 Sections Compliance and Disclosure Interpretation 139.13. If you use
defined terms
 when describing the method by which the price of the shares will be
determined,
 define such terms. Also clarify whether shares have been issued pursuant
to the Initial
 Pre-Paid Purchase of $4,330,000 and, if so, whether they are the
2,937,500 Pre-
 Delivery Shares. Explain whether $587 is the purchase price for the
Pre-Delivery
 Shares and, if so, how such price was determined. Assuming that the
Initial Pre-Paid
 Purchase has occurred, please state the Purchase Share Purchase Price
and the manner
 in which it was determined (e.g., initial listing reference price,
relevant VWAP).
 Revise to clarify the manner in which the purchase price of subsequent
Pre-Paid
 Purchases will be determined.
Plan of Distribution, page 62

12. Please revise to further clarify how the provisions of Regulation M may
prohibit
 Streeterville and any other distribution participants that are
participating in the
 distribution of the company s securities from (i) engaging in market
making
 activities (e.g., placing bids or making purchases to stabilize the
price of the common
 stock) while the equity line is in effect; and (ii) purchasing shares in
the open market
 while the equity line is in effect.
Exhibits

13. Please revise Exhibit 10.11 to include all material portions of the
agreement, including
 Exhibits A through E. For guidance, refer to Securities Act Sections
Compliance and
 Disclosure Interpretation 139.13 and Item 601(b)(2) of Regulation S-K.
 June 3, 2025
Page 4

 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.

 We also remind you that your registration statement must be on file at
least two
business days prior to the requested effective date and time. Refer to Rules
460 and 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 Nicholas Nalbantian at 202-551-7470 or Lilyanna Peyser at
202-551-
3222 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Joseph Lucosky
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