SecProbe.io

CORRESP
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    June 28, 2024

    VIA EDGAR

    United States Securities and Exchange Commission

    Division of Corporation Finance

    Office of Manufacturing

    100 F Street NE

    Washington, D.C. 20549

    Orrick, Herrington & Sutcliffe LLP

                                                                                    222
Berkeley St.

                                                                                Suite
2000

                                                                                Boston, MA 02116

                                                                                +1 (617) 880-1800

                                                                                orrick.com

                                                                                Albert W. Vanderlaan

                                                                                E  avanderlaan@orrick.com

                                                                                D +1 617-880-2219

Attn: Thomas Jones

Jay Ingram

Re: Serve Robotics Inc.

Registration Statement on Form S-1

Filed June 7, 2024

File No. 333-280071

Ladies and Gentlemen:

On behalf of our client, Serve
Robotics Inc., a Delaware corporation (the “Company”), we are writing to submit the Company’s responses to the comments
of the staff of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Commission”)
(the “Staff”) with respect to the above-referenced Registration Statement on Form S-1 that was filed with the Commission on
June 7, 2024 (the “Original Registration Statement”), contained in the Staff’s letter dated June 25, 2024 (the “Comment
Letter”).

The Company has publicly filed
via EDGAR its Amendment No. 1 to the Registration Statement on Form S-1 (“Amendment No. 1,” and together with Original Registration
Statement, the “Amended Registration Statement”), which reflects the Company’s responses to the comments received by
the Staff and certain updated information. For ease of reference, each comment contained in the Comment Letter is printed below in bold
and is followed by the Company’s response. All page references in the responses set forth below refer to page numbers in the Amended
Registration Statement. Capitalized terms used but not defined herein have the meanings set forth in the Amended Registration Statement.

Registration Statement on Form S-1 filed June 7, 2024

Management’s Discussion and Analysis, page 38

 1. Please include in your registration statement financial statements for the quarterly period ended March
31, 2024. Also, update your disclosure to include a management’s discussion and analysis of financial condition and results of operations
for the fiscal year ended December 31, 2023. For guidance, refer to Instruction 1 to paragraph (b) of Item 303 of Regulation S-K, which
requires the discussion to cover the periods covered by the financial statements included in the filing.

Response: We have included in
the Amended Registration Statement financial statements for the quarterly period ended March 31, 2024. Furthermore, we have revised our
disclosure on pages 43-44 of the Amended Registration Statement in response to the Staff’s comment.

Exhibit Index, page II-7

 2. Your legality opinion filed as Exhibit 5.1 relates to 4,813,041 shares of common stock being offered
by selling stockholders. However, it appears from the disclosure on the cover page of this registration statement that 2,708,479 shares
of common stock are issuable upon exercise of warrants. Please file a revised opinion that indicates, if true, that the shares of common
stock when issued will be validly issued, fully paid and nonassessable.

Response: We have revised our
legality opinion filed as Exhibit 5.1 to the Amended Registration Statement in response to the Staff’s comment.

* * *

June 28, 2024

Page 2

Please do not hesitate to
contact Albert Vanderlaan at (617) 880-2219 of Orrick, Herrington & Sutcliffe LLP with any questions or comments regarding this letter.

Sincerely,

/s/ Orrick, Herrington & Sutcliffe LLP

Orrick, Herrington & Sutcliffe LLP

cc: Ali Kashani, Serve Robotics Inc.