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June 18, 2024
Deanna White
Chief Executive Officer
Surf Air Mobility Inc.
12111 S. Crenshaw Blvd.
Hawthorne, CA 90250
Re:Surf Air Mobility Inc.
Registration Statement on Form S-1
Filed June 4, 2024
File No. 333-279928
Dear Deanna White:
            We have conducted a limited review of your registration statement and have the
following comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Form S-1 filed June 4, 2024
Risk Factors, page 7
1.We note you have incorporated your risk factor disclosure from your 2023 Form 10-K
which includes a general risk factor regarding compliance with the continued listing
standards of the NYSE.  Please revise this section to address the risks associated with
failing to meet the New York Stock Exchange continued listing standards.  To provide
context, discuss (i) the May 20, 2024 notice from the NYSE stating that the Company is
no longer in compliance with the NYSE continued listing standards due to the fact that the
Company’s average total market capitalization over a consecutive 30 trading-day period
was less than $50 million and, at the same time, its stockholders’ equity was less than $50
million and (ii) the April 2, 2024 notice stating that the average closing price of the
Company’s common stock was less than $1.00 over a consecutive 30 trading-day period
and that failure to regain compliance with these standards may result in the delisting of
your securities.

 FirstName LastNameDeanna White
 Comapany NameSurf Air Mobility Inc.
 June 18, 2024 Page 2
 FirstName LastName
Deanna White
Surf Air Mobility Inc.
June 18, 2024
Page 2
Plan of Distribution, page 25
2.We note your disclosure on page 25 that your selling stockholders may sell their securities
using various methods, including any method permitted pursuant to applicable law. Please
confirm your understanding that the retention by a selling stockholder of an underwriter
would constitute a material change to your plan of distribution requiring a post-effective
amendment.  Refer to your undertaking provided pursuant to Item 512(a)(1)(iii) of
Regulation S-K.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Anuja Majmudar at 202-551-3844 or Daniel Morris at 202-551-3314 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Peter Wardle