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CORRESP
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March 1, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549-3720

Attn: Kate Beukenkamp and Dietrich King

 Re: Galata Acquisition Corp. Amendment No. 1 to the Registration Statement on Form F-4, filed December 30, 2022 (File No. 333-269067).

Dear Ms. Beukenkamp
and Mr. King,

On behalf of Galata Acquisition
Corp. (“we,” “our,” or the “Company”), we submit this letter in response to the
comments from the staff (the “Staff”) of the Securities and Exchange Commission set forth in your letter dated January
26, 2023 (the “Comments”), with respect to the above referenced Registration Statement on Form F-4 as filed by the
Company on December 30, 2022 (the “F-4”). The Company is concurrently submitting via EDGAR this letter and Amendment
No. 1 to the F-4 (“Amendment No. 1”).

The Staff’s comments
are summarized below in italicized text, and our responses to the Staff’s comments are set out immediately under the restated comment.
Unless otherwise indicated, defined terms used herein have the meanings set forth in the F-4.

Cover Page

 1. Comment: We note that in addition to the Business Combination Proposal, or Proposal No. 1, Galata’s
shareholders will also be asked to consider and vote upon a proposal to change the multi-class structure of Galata, comprising of Class
A Ordinary Shares of Galata, Founders Shares and preference shares of Galata, to a single-class share structure of New Marti comprised
solely of Class A Ordinary Shares of New Marti and preference shares of New Marti. However, your discussion in the paragraphs immediately
prior does not address the conversion, for example, of Galata preference shares to New Marti preference shares. Please revise your disclosure
here and elsewhere, as appropriate, to address these shares and their treatment within the terms of the Business Combination Agreement,
including how these shares relate to your description of a single-class share structure for both Galata and New Marti. We note your discussion
elsewhere within your disclosure regarding preference shares, but note that the term “preference shares” is not defined outside
of Annex B.

Response:
In response to the Staff’s comment, the Company has revised the disclosure on the Cover Pages and on pages 7, 13, 16-17, 36, 108-109,
262-263 and 266 of Amendment No. 1. The Company respectfully advises the Staff that there are no Preference Shares outstanding and none
will be converted in connection with the Business Combination, but rather New Marti (i.e., Galata as of and following the Merger) will
change its authorized share capital and its share structure in connection with the Business Combination pursuant to the Proposed Articles
of Association, whereby the preference shares of New Marti will be authorized. The Founder Shares however will convert into Class A Ordinary
Shares, as described on the Cover Pages and pages 27, 90, 108, 152 and 169 of the F-4 and the Cover Pages and pages 28, 99, 117-118, 166
and 185 of Amendment No. 1.

 2. Comment: We note that on December 23, 2022, “the Company irrevocably and unconditionally
waived the Available Galata Cash Condition.” Please revise your disclosure as appropriate, including in the Selected Definitions
section beginning on page 6, to make clear which entity you are referring to when using the defined term “the Company.”

Response: In response to the Staff’s
comment, the Company has revised the disclosure on the Cover Pages and on pages 5, 30, and 127 of Amendment No. 1.

Selected Definitions, page 6

 3. Comment: Please revise your definition of “Eligible Marti Equityholder” to state
which, if any, holders of Marti equity are not included within this definition. If the definition includes all holders of Marti equity,
please state the same.

Response: In response to the Staff’s
comment, the Company has revised the disclosure on page 5 of Amendment No. 1.

 4. Comment: Please revise your definitions of the parties listed in this section, including Verdi,
Willkie, Barclays, B. Riley and Scura Partners, for example, to briefly describe the role each entity has in your Business Combination
or initial public offering. For example, we note that your disclosure on page 112 describes B. Riley as serving as underwriter in your
initial public offering.

Response: In response to the Staff’s comment,
the Company has revised the disclosure on pages 5-8 of Amendment No. 1.

    - 2 -

Questions and Answers About the Business Combination and the
General Meeting

Questions and Answers About the Business Combination and the General
Meeting, page 14

 5. Comment: Please revise this section to include a Q&A that addresses how much dilution non-redeeming
Galata stockholders may experience. Disclose all possible sources and the extent of dilution that stockholders who elect not to redeem
their shares may experience in connection with the business combination. Provide disclosure on the impact of each significant source of
dilutions, including the amount of equity held by founders, convertible securities, including warrants retained by redeeming stockholders,
at each of the redemption levels detailed in your sensitivity analysis, including any needed assumptions.

Response: In response to the Staff’s
comment, the Company has revised the disclosure on pages 16-17 of Amendment No. 1.

Q: Did the Galata Board obtain a
third-party valuation or fairness opinion..., page 15

 6. Comment: Please revise your disclosure here and in your section titled “Fairness Opinion
of Scura Partners to Galata’s Board of Directors” on page 119, for example, to make clear the scope of Scura’s fairness
opinion. Cautionary language should be included noting that the fairness opinion addresses fairness to all Galata stockholders as a group
as opposed to only those stockholders unaffiliated with the Sponsor or its affiliates.

Response: In response to the Staff’s
comment, the Company has revised the disclosure on pages 15, 37 and 131 of Amendment No. 1.

Q: What shall be the relative equity
stakes of Galata’s current shareholders..., page 16

 7. Comment: We note that the answer presents the equity stake breakdown by percentage based upon
no redemptions or full redemptions. Please revise to indicate such ownership interests to reflect at least one additional redemption scenario
in between no redemptions and full redemptions. Make conforming changes throughout the proxy statement/prospectus.

Response: In response to the Staff’s
comment, the Company has revised the disclosure on pages 11, 89, 99, 121-122 and 263 of Amendment No. 1 and throughout the proxy statement/prospectus.

Q: I am a Galata shareholder. Do
I have redemption rights?, page 19

 8. Comment: Please expand this Q&A to discuss the Founders Shares, including related redemption
rights. We note that certain shareholders, including holders of the Founders Shares appear to have agreed to waive their redemption rights.
Please revise your disclosure to describe any consideration provided in exchange for this agreement.

Response: In response to the Staff’s
comment, the Company has revised the disclosure on page 20 of Amendment No. 1.

    - 3 -

Risk Factors

Risks Related to Marti

Risks Related to Marti’s Business and History - We reply on
third parties maintaining open marketplaces to distribute our application..., page 43

 9. Comment: We note your disclosure that “[s]ubstantially all of our revenue is generated
through our mobile application” and your mobile application is available for download to your users through Apple App Store, Google
Play Store, and Huawei AppGallery. We also note your discussion regarding the impact changes in the relationship with any of these three
third parties would have on your business. Please revise this risk factor to discuss whether there are any additional third party mobile
application platforms and digital storefronts that may be available to distribute your platform to customers or if your business model
is substantially dependent on these three providers.

Response: In response to the Staff’s
comment, the Company has revised the disclosure on page 45 of Amendment No. 1.

Risks Related to Marti’s Intellectual Property and Technology

Our service relies on GPS and other Global Satellite Navigation
Systems (“GNSS”). , page 59

 10. Comment: Please revise the title of this risk factor to include a brief description of the specific
impact this risk may have on your business as well as expand your discussion of what specific aspects of your “service” are
tied to reliance on GNSS.

Response:
In response to the Staff’s comment, the Company has revised the disclosure on page 63 of Amendment No. 1.

    - 4 -

We collect, store, process and use personal information and other
customer data..., page 62

 11. Comment: In this risk factor you state that you “collect, store, process and use personal
information and other user data.” Please revise your disclosure to discuss the general application of the General Data Protection
Regulation, or GDPR, to your business as well as any risks related to the applicability of this regulation to your business. Additionally,
we note your risk factor on page 61 titled “Government regulation of the Internet and user privacy is evolving...” which discusses
the application of “laws specifically governing the Internet and user privacy, including the processing and storage of personal
information.”

Response:
The Company respectfully acknowledges the Staff’s comment and submits to the Staff that Marti does not have any establishments
in the European Union (the “EU”) and does not have any entities or affiliates in the EU. Although individuals residing
outside of Türkiye can register on Marti’s application to receive Marti’s services within Türkiye, Marti does
not target or otherwise direct its services to individuals outside Türkiye. According to Article 3 of the GDPR, GDPR’s
territorial scope is determined as follows:

(1) This Regulation applies to the processing
of personal data in the context of the activities of an establishment of a controller or a processor in the Union, regardless of whether
the processing takes place in the Union or not.

(2) This Regulation applies to the processing
of personal data of data subjects who are in the Union by a controller or processor not established in the Union, where the processing
activities are related to:

 · the offering of goods or services, irrespective of whether a payment of the data subject is required, to such data subjects in the
Union; or

 · the monitoring of their behavior as far as their behavior takes place within the Union.

Because Marti does not have an establishment,
entity or affiliate in the EU, (1) above does not apply. Similarly, (2) sets forth requirements from the European Data Protection Board’s
guidelines and does not apply to Marti's operations. Marti does not offer goods or services to data subjects in the EU or monitor their
behavior within with EU and, therefore, does not target data subjects in the EU. Accordingly, Marti does not fall within the territorial
scope of the GDPR and its operations are not subject to the GDPR.

Risks Related to Being a Public Company,
page 75

 12. Comment: Please highlight the material risks to public warrant holders, including those arising from differences between
private and public warrants. Clarify whether recent common stock trading prices exceed the threshold that would allow the company to redeem
public warrants. Clearly explain 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 risk factor beginning with “Galata may redeem the Public Warrants
prior to their exercise or expiration...” on page 79.

Response: The Company respectfully acknowledges the
Staff’s comment, and note that the requested disclosure was included in the risk factor on pages 94-95 and 104-105 of the F-4, and
is included on page 86 and on pages 103-104 and 114-115 Amendment No. 1.

    - 5 -

Risks Related to the Redemption,
page 94

 13. Comment: Revise your disclosure to discuss the material risk to unaffiliated investors presented by taking Marti public
through a merger rather than an underwritten offering, including the absence of due diligence conducted by an underwriter that would be
subject to liability for any material misstatements or omissions in this registration statement, for example.

Response: The Company respectfully acknowledges the
Staff’s comment, and note that the requested disclosure was included in the risk factor on page 85 of the F-4, and is included on
page 94 Amendment No. 1.

The Business Combination

Background of Business Combination, page 111

 14. Comment: In the section you state that Galata management initially focused the search for an acquisition target on the insurance
industry in Turkey and note the attractive features of this market. Additionally, Galata identified a number of potential targets that
were potentially for sale at an attractive price. Please revise your disclosure to briefly discuss what factors led you to explore acquisitions
in other industries, including the micromobility industry where Marti operates.

Response: In response to the Staff’s comment,
the Company has revised the disclosure on pages 123-124 of Amendment No. 1.

 15. Comment: We note that on June 21, 2021, Freifeld and Tanzer traveled to Turkey to meet with certain Turkish banking contacts,
survey then-current Callaway investments and conduct diligence on new investment opportunities on behalf of Callaway and during that trip,
they visited Marti headquarters. Please revise your disclosure to provide additional detail regarding how the visit to Marti headquarters
transpired and was arranged given that the characterization of the trip was largely to meet with existing Callaway contacts and survey
existing Callaway investments, and Tanzer and Durgan had ceased regular communication at the end of 2020.

Response: In response to the Staff’s comment,
the Company has revised the disclosure on page 123 of Amendment No. 1.

 16. Comment: You state that between August 23, 2021 and September 2, 2021, Galata entered into confidentiality agreements with
four of the potential acquisition targets, including Marti. Please revise your disclosure to state whether Company A, which along with
Marti you ultimately chose to pursue as a potential acquisition target, was also one of the four potential acquisition targets that entered
into a confidentiality agreement with Galata. We note your disclosure on page 114
regarding Company A.

Response: In response to the Staff’s comment,
the Company has revised the disclosure on pages 124-125 of Amendment No. 1.

    - 6 -

 17. Comment: Please expand your disclosure to discuss in greater detail the respective merits and limitations of the potential
business combinations with Marti and Company A that representatives from Galata’s management presented to the Galata Board on August
19, 2021 and the Board’s consideration of these factors. We note that the Board authorized Galata management to pursue both acquisitions.

Response: In response to the Staff’s comment,
the Company has revised the disclosure on pages 123-125 of Amendment No. 1.

 18. Comment: Please revise your disclosure to discuss how Galata arrived at an initial enterprise value of approximately $1.1
billion for Marti as outlined in the draft indication of interest letter sent on August 21, 2021. We note that Marti had previously indicated
that their expectation of a pre-money valuation for Marti was $1 billion. Further, please expand the disclosure to discuss what terms
or other revisions were negotiated in the exchange of the drafts of the Confidentiality Agreement between Galata and Marti.

Response: In response to the Staff’s comment,
the Company has revi