SecProbe.io

CORRESP
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    O’Melveny
    & Myers LLP

    Times
    Square Tower

    7
    Times Square

    New
    York, NY 10036

    T:
    +1 212 326-2000

    F:
    +1 212 326-2061

    omm.com

VIA
EDGAR

September
19, 2023

Ms.
Irene Barberena-Meissner

Mr.
Daniel Morris

Division
of Corporation Finance

Office
of Energy & Transportation

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Surf
Air Mobility Inc.

Response
to the Staff’s Comments on Draft Registration Statement on Form S-1 Submitted on August 3, 2023

CIK
No. 0001936224

Dear
Ms. Barberena-Meissner and Mr. Morris:

On
behalf of our client, Surf Air Mobility Inc., a Delaware corporation (the “Company”), we are hereby submitting to
the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) this letter
setting forth the Company’s responses to the comments contained in the Staff’s letter dated August 30, 2023 regarding the
Company’s Draft Registration Statement on Form S-1 submitted via EDGAR to the Commission on August 3, 2023 (the “Draft
Registration Statement”).

Concurrently
with the submission of this letter, the Company is filing the Company’s Registration Statement on Form S-1 (the “Registration
Statement”) via EDGAR to the Commission for review.

The
Staff’s comments are repeated below in bold and are followed by the Company’s responses. To the extent helpful, we have included
page references in the Registration Statement where the language addressing a particular comment appears. Capitalized terms used but
not otherwise defined herein have the meanings set forth in the Registration Statement.

Draft
Registration Statement on Form S-1

Cover
Page

 1. We
                                            note your disclosure that your prospectus relates, in part, to the registration of the resale
                                            of up to a to be disclosed number of shares of Common Stock to be issued to GEM in connection
                                            with the Share Subscription Facility. Please revise your disclosure here and elsewhere in
                                            your prospectus to separately describe the registration for resale of the 1,300,000 shares
                                            of Common Stock that were issued to GEM following your direct listing for a purchase price
                                            of $0.01 per share, pursuant to the Share Subscription Facility.

Response:
The Company respectfully acknowledges the Staff’s comment and has updated the disclosure on the cover and on pages 105-106, 114,
139 and 167 of the prospectus to separately describe the 1,300,000 shares that were issued to GEM.

 2. Please
                                            revise to provide the offering price disclosure by Item 501(b)(3) of Regulation S-K.

Response:
The Company respectfully acknowledges the Staff’s comment and has updated the disclosure on the cover of the prospectus to provide
the offering price disclosure required by Item 501(b)(3) of Regulation S-K.

 3. Please
                                            revise disclosures that appear to relate to your direct listing IPO. For example, you disclose
                                            here that “[u]nlike an initial public offering, the resale by the Selling Stockholder
                                            is not being underwritten by any investment bank.” You also disclose here that “[s]uch
                                            sales, if any, will be made through brokerage transactions on the New York Stock Exchange
                                            (the “NYSE”),” which is inconsistent with your Plan of Distribution disclosure
                                            on pages 172-173.

Response:
The Company respectfully acknowledges the Staff’s comment and has updated the disclosure on the cover to remove disclosures relating
to the direct listing and to be consistent with the Plan of Distribution.

Plan
of Distribution, page 173

 4. We
                                            note your disclosure that the Selling Stockholder and any broker-dealers or agents that are
                                            involved in selling the Common Stock may be deemed to be “underwriters” within
                                            the meaning of the Securities Act in connection with such sales. Please revise to indicate
                                            that Selling Stockholder is an underwriter.

Response:
The Company respectfully acknowledges the Staff’s comment and has updated the disclosure to indicate the Selling Stockholder is
an underwriter within the meaning of the Securities Act in connection with such sales.

General

 5. Please
                                            revise this draft registration statement, as necessary, to reflect corresponding revisions
                                            made in response to our comments on the draft registration statement on Form S-1 that you
                                            filed concurrently with this draft registration statement.

Response:
The Company respectfully acknowledges the Staff’s comment and has reflected corresponding revisions made in response to the comments
on the registration statement filed concurrently with this registration statement.

If
you have any questions regarding the Registration Statement, please contact Jeeho Lee by telephone at 212-326-2266 or via e-mail at jeeholee@omm.com.

    Very truly yours,

    /s/ Jeeho
    M. Lee

cc:

Yolanda
Guobadia, Staff Accountant

Robert
Babula, Staff Accountant

Sudhin
Shahani, Chief Executive Officer, Surf Air Mobility Inc.

C.
Brophy Christensen, Partner, O’Melveny & Myers LLP

Noah
Kornblith, Partner, O’Melveny & Myers LLP

Yoon-jee
Kim, Counsel, O’Melveny & Myers LLPw