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 March 11, 2025

Francis Davidson
Chief Executive Officer
Sonder Holdings Inc.
447 Sutter St. Suite 405, #542
San Francisco, California 94108

 Re: Sonder Holdings Inc.
 Schedule 13D filed January 15, 2025 by Francis Davidson
 File No. 005-92541
Dear Francis Davidson:

 We have conducted a limited review of the above-captioned filing and
have the
following comments.

 Please respond to this letter by amending the filing or by providing
the requested
information. If you do not believe our comments apply to your facts and
circumstances or
that an amendment is appropriate, please advise us why in a response letter.

 After reviewing any amendment to the filing and any information provided
in
response to these comments, we may have additional comments.

Schedule 13D filed January 15, 2025
General

1. We note that the event reported as requiring the filing of the Schedule
13D was
 September 30, 2024. Rule 13d-1(a) of Regulation 13D-G requires the
filing of a
 Schedule 13D within five business days after the date beneficial
ownership of more
 than five percent of a class of equity securities specified in Rule
13d-1(i)(1) was
 acquired. Based on the September 30, 2024 event date, the Schedule 13D
submitted
 on January 15, 2025 was not timely filed. Please advise us why the
Schedule 13D was
 not filed within the required five business days after the date of the
acquisition.
Item 5, page 1

2. We note your disclosure in Item 5(c) that "[e]xcept as otherwise set
forth in Item 4 of
 this Schedule 13D, Mr. Davidson has not engaged in any transaction with
respect to
 the Common Stock during the sixty days prior to the date of filing this
Schedule
 13D." Please revise to provide the requisite disclosure with respect to
all transactions
 March 11, 2025
Page 2

 in the securities between the deadline for timely filing the Schedule
13D and the
 actual filing of the Schedule 13D. In amending the Schedule 13D to
include the
 required disclosures, please be advised that the Instruction to Item
5(c) requires the
 beneficial owner to "describe," at a minimum, the following: "(1) The
identity of the
 person covered by Item 5(c) who effected the transaction; (2) the date
of transaction;
 (3) the amount of securities involved; (4) the price per share or unit;
and (5) where
 and how the transaction was effected."
 We remind you that the filing person is responsible for the accuracy
and adequacy of
his disclosures, notwithstanding any review, comments, action or absence of
action by the
staff.

 Please direct any questions to Blake Grady at 202-551-8573 or Nicholas
Panos at
202-551-3266.

 Sincerely,

 Division of
Corporation Finance
 Office of Mergers &
Acquisitions
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