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March 27, 2023
Kemal Kaya
Chief Executive Officer
Galata Acquisition Corp.
2001 S Street NW, Suite 320
Washington, DC 20009
Re:Galata Acquisition Corp.
Amendment No. 1 to Registration Statement on Form F-4
Filed March 1, 2023
File No. 333-269067
Dear Kemal Kaya:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our January 26, 2023 letter.
Amendment No. 1 to Registration Statement on Form F-4 filed March 1, 2023
Risks Related to Legal Matters and Regulations
Action by governmental authorities to restrict access..., page 64
1.We note your revisions regarding district municipalities in Istanbul expressing concerns
regarding scooter usage and requesting scooter operators to install scooter parking spots in
the congested areas, which may result in additional capital expenditures for operators.
Please revise this risk factor to disclose whether you have received any such notice(s)
from district municipalities.

 FirstName LastNameKemal  Kaya
 Comapany NameGalata Acquisition Corp.
 March 27, 2023 Page 2
 FirstName LastName
Kemal  Kaya
Galata Acquisition Corp.
March 27, 2023
Page 2
Risk Factors
Risks Related to Marti
Risks Related to Being a Public Company
Galata may redeem the Public Warrants prior to their exercise or expiration..., page 86
2.We note your response to comment 12 and reissue in part. Please revise this risk factor to
clarify whether recent common stock trading prices exceed the threshold that would allow
the company to redeem public shares. Additionally, please discuss here the steps, if any,
the company will take to notify all shareholders, including beneficial owners, regarding
when the warrants become eligible for redemption. We note your disclosure in your risk
factor on page 97 titled "Galata may redeem unexpired Galata Warrants prior to their
exercise at a time..." disclosing that you have no obligation to notify holders of the
warrants that they have become eligible for redemption.
The Business Combination
Background of Business Combination, page 124
3.We note your response to comment 18, including a description of how Galata arrived at an
initial enterprise value of approximately $1.1 billion for Marti based on a 10x multiple of
pro forma run-rate net revenue as "detailed by Marti management in prior presentations
and discussions with Galata." Please revise your disclosure to clarify which prior
presentations by Marti that you are referring to here. We note the inclusion of an investor
presentation as Exhibit 99.3 to your Form 8-K filed August 1, 2022 in connection with
entry into the Business Combination Agreement.
4.Please expand your disclosure to discuss how you reached multiple of 10x pro forma run-
rate revenue as a useful multiple, for example, by disclosing and discussing the
projections used in reaching this multiple, comparison competitor multiples considered,
and the material assumptions underlying the revenue projections for Marti as well as the
limitations of the projections. We note that on page 139 you state that "the Galata Board
reviewed certain financial projections prepared by Marti through the 2023 year-end."
The Business Combination
Interests of Certain Persons in the Business Combination, page 144
5.We note your response to comment 24 and reissue in part. Please revise your disclosure to
quantify the aggregate dollar amount and describe the nature of what the Sponsor and its
affiliates have at risk that depends on the completion of the Business Combination. We
note your revisions that the Sponsor paid an aggregate of $7,250,000 for Private
Placement Warrants that would expire worthless if the Business Combination is not
consummated as well as the fact the Sponsor paid an aggregate of $25,000 for the
Founders Shares. Please include the current value of loans extended, fees due, and out-of-
pocket expenses for which the Sponsor and its affiliates are awaiting reimbursement.

 FirstName LastNameKemal  Kaya
 Comapany NameGalata Acquisition Corp.
 March 27, 2023 Page 3
 FirstName LastName
Kemal  Kaya
Galata Acquisition Corp.
March 27, 2023
Page 3
Key Metrics and Non-GAAP Financial Measures, page 229
6.We note your response to comment 40 and reissue the comment.  Please address the
following:
•You state that you incurred additional expense from a one-time amendment of
custom duties.  Please explain whether the customs tax provision expense related to
only e-scooters imported in 2021 or a cumulative duty for e-scooters imported from
2019-2021.
•You state you do not foresee a similar level of uncollectible receivables to recur in
the future.  However, we note that these expenses were recognized in multiple
periods and appear recurring.  Additionally, the nature of these expenses related to
uncollectible receivables appear to be normal, recurring cash operating expense
required to generate revenue.
•You also state you do not foresee a similar level of accounts payable adjustments to
recur in the future.  However, losses associated with advances to suppliers appear to
be normal, recurring cash operating expense required to generate revenue.
•Please revise or advise.  Refer to Question 100.01 of the Commission’s Non-GAAP
Compliance and Disclosure Interpretations.
Results of Operations, page 234
7.We note your responses to comments 41 and 42 and reissue comment 42, in part.  Please
expand your results of operations discussion where multiple drivers are responsible for the
changes, please quantify the effect for each driver identified and the underlying causes for
these changes.  In addition, quantify the effects of changes in price on revenues, where
appropriate, for each period presented.  Please explain and address any known or expected
trends, such as seasonality, with respect to revenues and cost of revenues for the
foreseeable future.  Please discuss any events that may cause a material change in the
relationship between revenues and cost of revenues.  Refer to Item 303(a) of Regulation
S-K.
Marti Technologies Inc. Financial Statements, page F-3
8.Please revise the headers for Marti Technologies Inc. interim financial statements and
footnotes to clearly label them as “Unaudited.”

 FirstName LastNameKemal  Kaya
 Comapany NameGalata Acquisition Corp.
 March 27, 2023 Page 4
 FirstName LastName
Kemal  Kaya
Galata Acquisition Corp.
March 27, 2023
Page 4
2 - Basis of Presentation and Going Concern
2.4 Restatement of Interim Financial Statements, page F-11
9.Please expand your disclosures to quantify the amount of error in notes 2.4.1 through
2.4.15 as the amounts of “restatement” in the balance sheet and the statement of
operations includes a combination of multiple errors.  For example, it is unclear the
amount of depreciation that is included in cost of revenues restatement for the period
ended September 30, 2022.  Additionally, expand your disclosure in sufficient detail to
more fully explain the nature and reasons for the identified errors.  Refer to ASC 250-10-
50-7.
General
10.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. Please also tell us whether anyone or any
entity associated with or otherwise involved in the transaction, such as the target, 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. Further, if
applicable, 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, if applicable, 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.
            You may contact Nasreen Mohammed at 202-551-3773 or Lyn Shenk at 202-551-3380 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Kate Beukenkamp at 202-551-3861 or Dietrich King at 202-551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Michael E. Brandt