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CORRESP
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Pontem
Corporation

1140 Avenue of the Americas, 9th Floor

New York, New York 10036

November
22, 2022

VIA EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Office of
Real Estate & Construction

100 F Street,
NE

Washington,
DC 20549

Attention:
Isabel Rivera, James Lopez

RE:
Pontem Corporation

Preliminary Proxy Statement on Schedule 14A

Filed November 14, 2022

File No. 001-39882

Ladies and
Gentlemen:

This
letter sets forth the responses of Pontem Corporation (the “Company”) to the comments of the staff of the Division of Corporation
Finance, Office of Real Estate & Construction (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
set forth in your letter, dated November 21, 2022, with respect to the Company’s Preliminary Proxy Statement on Schedule 14A, filed
on November 14, 2022, File No. 001-39882 (the “Proxy Statement”).

Set
forth below is the Company’s response to the Staff’s comments. Capitalized terms used but not otherwise defined herein shall
have the meanings ascribed thereto in the Proxy Statement. For your convenience, the Staff’s comment is reprinted in bold below,
followed by the Company’s response thereto.

Securities
and Exchange Commission

November
22, 2022

Page 2

Preliminary
Proxy Statement on Schedule 14A filed November 14, 2022

General

1.
Staff’s Comment: With a view toward disclosure, please tell
us whether your sponsor is, is controlled by, or has substantial ties with a non-U. S. person. If so, also include risk factor disclosure
that addresses how this fact could impact your ability to complete your initial business combination. For instance, discuss the risk
to investors that you may not be able to complete an initial business combination with a U.S. target company should the transaction be
subject to review by a U.S. government entity, such as the Committee on Foreign Investment in the United States (CFIUS), or ultimately
prohibited. Disclose that as a result, the pool of potential targets with which you could complete an initial business combination may
be limited. Further, disclose that the time necessary for government review of the transaction or a decision to prohibit the transaction
could prevent you from completing an initial business combination and require you to liquidate. Disclose the consequences of liquidation
to investors, such as the losses of the investment opportunity in a target company, any price appreciation in the combined company, and
the warrants, which would expire worthless.

Response:
The Company acknowledges the Staff’s comment and advises the Staff that Pontem LLC, the Company’s sponsor, is not, is not
controlled by, and has no substantial ties with a non-U.S. person.

*
* * * *

Securities
and Exchange Commission

November
22, 2022

Page 3

We
respectfully request the Staff’s assistance in completing the review of the Proxy Statement as soon as possible. Please contact
Debbie Yee of Kirkland & Ellis LLP at (713) 836-3630, respectively, with any questions or further comments regarding the responses
to the Staff’s comments.

    Sincerely,

    /s/
    Hubertus Muehlhaeuser

    Name:
    Hubertus Muehlhaeuser

    Title:
    Chief Executive Officer

Via
E-mail:

  cc:
  Debbie Yee, P.C., Kirkland & Ellis
  LLP

  Nina Murphy