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 Document VIA TRANSPORTATION, INC. 114 5 th Ave, 17 th Floor New York, NY 10011 September 9, 2025 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Technology 100 F Street, N.E. Washington, DC 20549-3561 Attn: Laura Veator Stephen Krikorian Mariam Mansaray Jan Woo Re: Via Transportation, Inc. (the “Company”) Registration Statement on Form S-1 (Registration No. 333-289624) Ladies and Gentlemen: Pursuant to Rule 461(a) of the General Rules and Regulations under the Securities Act of 1933, as amended, we respectfully request that the effective date of the Company's Registration Statement on Form S-1 (File No. 333-289624) be accelerated by the Securities and Exchange Commission to 4:00 p.m. Eastern Time on September 11, 2025, or as soon as practicable thereafter, or at such other time as the Company or its legal counsel may request by telephone to the staff of the Securities and Exchange Commission. We request that we be notified of such effectiveness by a telephone call to Ryan Dzierniejko of Skadden, Arps, Slate, Meagher & Flom LLP at (212) 735-3712 and that such effectiveness also be confirmed in writing. Very truly yours, Via Transportation, Inc. By: /s/ Daniel Ramot Name: Daniel Ramot Title: Chief Executive Officer cc: Clara Fain, Chief Financial Officer, Via Transportation, Inc. Erin H. Abrams, Chief Legal Officer, Via Transportation, Inc. Ryan J. Dzierniejko, Skadden, Arps, Slate, Meagher & Flom LLP Jeremy Winter, Skadden, Arps, Slate, Meagher & Flom LLP Marc D. Jaffe, Latham & Watkins LLP Nathan Ajiashvili, Latham & Watkins LLP Alison Haggerty, Latham & Watkins LLP 2

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 Document GOLDMAN SACHS & CO. LLC 200 West Street New York, New York 10282 September 9, 2025 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Technology 100 F Street, N.E. Washington, DC 20549-3561 Attn: Laura Veator Stephen Krikorian Mariam Mansaray Jan Woo Re: Via Transportation, Inc. Registration Statement on Form S-1 Filed August 15, 2025 File No. 333-289624 Acceleration Request Requested Date: September 11, 2025 Requested Time: 4:00 P.M. Eastern Time Ladies and Gentlemen: Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we, as the representative of the several underwriters (the “Representative”), hereby join in the request of Via Transportation, Inc., a Delaware company (the “Company”), that the effective date of the above-referenced Registration Statement on Form S-1 be accelerated so that it will be declared effective at 4:00 p.m. Eastern Time, on September 11, 2025, or as soon thereafter as practicable, or at such other time thereafter as the Company or its outside counsel, Skadden, Arps, Slate, Meagher & Flom LLP, may request by telephone to the staff of the Securities and Exchange Commission. Pursuant to Rule 460 under the Securities Act, we, as the Representative, wish to advise you that we will take reasonable steps to secure adequate distribution of the preliminary prospectus to underwriters, dealers, institutions and others prior to the requested effective time of the Registration Statement. We, the undersigned Representative, hereby represent that we are in compliance and will comply, and have been informed by the other participating underwriters that they are in compliance and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the offering pursuant to the above-referenced Registration Statement and Preliminary Prospectus. [ Signature Page Follows ] Very truly yours, Goldman Sachs & Co. LLC As Representative of the several Underwriters GOLDMAN SACHS & CO. LLC By: /s/ Danielle Freeman Name: Danielle Freeman Title: Managing Director

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 Document SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP ONE MANHATTAN WEST FIRM/AFFILIATE OFFICES NEW YORK, NY 10001 — TEL: (212) 735-3000 FAX: (212) 735-2000 www.skadden.com — BOSTON CHICAGO HOUSTON LOS ANGELES PALO ALTO WASHINGTON, D.C. WILMINGTON — ABU DHABI BEIJING BRUSSELS FRANKFURT HONG KONG LONDON MUNICH PARIS SAO PAULO SEOUL SINGAPORE TOKYO TORONTO September 3, 2025 VIA EDGAR Securities and Exchange Commission Division of Corporation Finance Office of Technology 100 F Street, N.E. Washington, DC 20549-3561 Attn: Laura Veator Stephen Krikorian Mariam Mansaray Jan Woo Re: Via Transportation, Inc. Registration Statement on Form S-1 Filed August 15, 2025 File No. 333-289624 On behalf of our client, Via Transportation, Inc., a Delaware corporation (the “ Company ”), we hereby provide responses to comments received from the staff (the “ Staff ”) of the Securities and Exchange Commission (the “ Commission ”) by letter dated August 28, 2025 Securities and Exchange Commission September 3, 2025 Page 2 (the “ Comment Letter ”) with respect to the above-referenced Registration Statement on Form S-1 filed with the Commission on August 15, 2025. Concurrently with the submission of this letter, the Company is filing, through the Commission’s Electronic Data Gathering, Analysis and Retrieval (“ EDGAR ”) system, an Amendment No. 1 to the Registration Statement on Form S-1 (“ Amendment No. 1 ”) in response to the Staff’s comments and to reflect certain other changes. The headings and paragraph numbers in this letter correspond to those contained in the Comment Letter and, to facilitate the Staff’s review, we have reproduced the text of the Staff’s comments in bold and italics below. All references to page numbers and captions (other than those in the Staff’s comments and unless otherwise stated) correspond to the page numbers and captions in Amendment No. 1. Registration Statement on Form S-1 Prospectus Summary, page 1 1. We note the following statement on page 7, “In the United States alone, nearly 8 billion public transit trips occur annually.” Provide support as to where the data comes from or how it was derived. In all instances where you use industry and market data, please ensure that you have disclosed your support for all such statements, including the names and dates of third party sources Response : The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has amended its disclosure on pages 7 and 119 of Amendment No. 1 to address the Staff’s comment. Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Comparison of the Six Months Ended June 30, 2024 and 2025 Revenue, page 91 2. Please disclose your Platform Net Revenue Retention Rate for the six months ended June 30, 2025, and clarify how the percentage change in revenue for the six months ended June 30, 2025 correlates to the percentage change in Platform Net Revenue Retention Rate and the percentage change in number of customers that you disclose. Response : The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has amended its disclosure on page 93 of Amendment No. 1 to disclose Platform Net Revenue Retention Rate for the twelve months ended June 30, 2025. As disclosed on page 87 of Amendment No. 1, Platform Net Revenue Retention Rate 2 Securities and Exchange Commission September 3, 2025 Page 3 regularly fluctuates due to the timing of large contracts, and therefore the Company calculates Platform Net Revenue Retention Rate only for annual periods. Consolidated Financial Statements for the Six Months Ended June 30, 2025 and 2024 Notes to Consolidated Financial Statements 17. Subsequent Events, page F-55 3. Please disclose the grant date fair value of the CEO Service Awards and the CEO Stock Price Awards granted subsequent to June 30, 2025. Clarify the fair value per share of the underlying equity interest used in determining the fair value of these awards. To the extent there is a material difference between this fair value and the midpoint of your offering range, fully explain the assumptions used and the reason for the difference. Response : The Company respectfully acknowledges the Staff’s comment and advises the Staff that the grant of the CEO Service Award and CEO Stock Price Award is contingent on the effectiveness of the Registration Statement. The grant date for the CEO Service Award and CEO Stock Price Award will be the date of the effectiveness of the Registration Statement, and the grant date fair value of the CEO Service Award and the CEO Stock Price Award will be determined based on the final offering price for the Company’s initial public offering (“ IPO Price ”). The grant date fair value of the CEO Service Award will be equal to the IPO Price multiplied by the number of restricted stock units issued (362,108). The grant date fair value of the CEO Stock Price Award will be determined using a Monte Carlo valuation model that incorporates the likelihood of meeting the stock price targets and for which the inputs will be the IPO Price and various assumptions including expected stock price volatility, risk-free interest rates, and expected dividend yield, as of the date of the effectiveness of the Registration Statement. The Company has revised its disclosure on pages 156, 157 and F-55 of Amendment No. 1 to clarify these points. 4. Disclose the number of restricted stock units associated with the CFO Stock Price Award and the Executive Service Awards granted subsequent to June 30, 2025, and the basis upon which the number of units is determined. Response : The Company respectfully acknowledges the Staff’s comment and advises the Staff that the number of restricted stock units associated with the CFO Stock Price Award will be determined by dividing the notional value of $20.0 million by the IPO Price and 3 Securities and Exchange Commission September 3, 2025 Page 4 the number of restricted stock units associated with the Executive Service Awards will be determined by dividing the grant date fair value of the awards by the IPO Price. The Company has revised its disclosure on pages 158, F-55 and F-56 of Amendment No. 1 to clarify these points. 5. To the extent the compensation cost associated with the awards granted subsequent to June 30, 2025 will have a material impact on your financial statements, tell us how you considered disclosing the assumptions and valuation methodologies used in determining the fair value of these awards. Response : The Company respectfully advises the Staff that it has revised the disclosure on page F-55 of the Amendment to disclose the assumptions and valuation methodologies that are expected to be used in determining the fair value of the awards granted subsequent to June 30, 2025 and contingent on the IPO, and to note that these awards could have a material impact on the Company’s financial statements. General 6. Please provide balanced disclosure in the graphics by including the net loss for the same periods that you disclose revenue growth and annual run-rate revenue. Response : The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised the graphic in the forepart of Amendment No. 1 to address the Staff’s comment. * * * * * 4 Securities and Exchange Commission September 3, 2025 Page 5 Please contact me at (212) 735-3712 or ryan.dzierniejko@skadden.com if the Staff has any questions or requires additional information. Very truly yours, /s/ Ryan J. Dzierniejko cc: Daniel Ramot, Chief Executive Officer, Via Transportation, Inc. Clara Fain, Chief Financial Officer, Via Transportation, Inc. Erin H. Abrams, Chief Legal Officer, Via Transportation, Inc. Jeremy Winter, Skadden, Arps, Slate, Meagher & Flom LLP Marc D. Jaffe, Latham & Watkins LLP Nathan Ajiashvili, Latham & Watkins LLP Alison Haggerty, Latham & Watkins LLP 5

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<TEXT>
 August 28, 2025

Daniel Ramot
Chief Executive Officer
Via Transportation, Inc.
114 5th Ave, 17th Floor
New York, NY 10011

 Re: Via Transportation, Inc.
 Registration Statement on Form S-1
 Filed August 15, 2025
 File No. 333-289624
Dear Daniel Ramot:

 We have reviewed 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.

Registration Statement on Form S-1
Prospectus Summary, page 1

1. We note the following statement on page 7, "In the United States alone,
nearly 8
 billion public transit trips occur annually." Provide support as to
where the data comes
 from or how it was derived. In all instances where you use industry and
 market data, please ensure that you have disclosed your support for all
such
 statements, including the names and dates of third party sources.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Comparison of the Six Months Ended June 30, 2024 and 2025
Revenue, page 91

2. Please disclose your Platform Net Revenue Retention Rate for the six
months ended
 June 30, 2025, and clarify how the percentage change in revenue for the
six months
 August 28, 2025
Page 2

 ended June 30, 2025 correlates to the percentage change in Platform Net
Revenue
 Retention Rate and the percentage change in number of customers that you
disclose.
Consolidated Financial Statements for the Six Months Ended June 30, 2025 and
2024
Notes to Consolidated Financial Statements
17. Subsequent Events, page F-55

3. Please disclose the grant date fair value of the CEO Service Awards and
the CEO
 Stock Price Awards granted subsequent to June 30, 2025. Clarify the fair
value per
 share of the underlying equity interest used in determining the fair
value of these
 awards. To the extent there is a material difference between this fair
value and the
 midpoint of your offering range, fully explain the assumptions used and
the reason for
 the difference.
4. Disclose the number of restricted stock units associated with the CFO
Stock Price
 Award and the Executive Service Awards granted subsequent to June 30,
2025, and
 the basis upon which the number of units is determined.
5. To the extent the compensation cost associated with the awards granted
subsequent to
 June 30, 2025 will have a material impact on your financial statements,
tell us how
 you considered disclosing the assumptions and valuation methodologies
used in
 determining the fair value of these awards.
General

6. Please provide balanced disclosure in the graphics by including the net
loss for the
 same periods that you disclose revenue growth and annual run-rate
revenue.
 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 Laura Veator at 202-551-3716 or Stephen Krikorian at
202-551-3488 if
you have questions regarding comments on the financial statements and related
matters. Please contact Mariam Mansaray at 202-551-6356 or Jan Woo at
202-551-3453 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Technology
cc: Ryan J. Dzierniejko
</TEXT>
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 June 17, 2025

Daniel Ramot
Chief Executive Officer
Via Transportation, Inc.
114 5th Ave, 17th Floor
New York, NY 10011

 Re: Via Transportation, Inc.
 Amendment No. 1 to Draft Registration Statement on Form S-1
 Submitted June 3, 2025
 CIK No. 0001603015
Dear Daniel Ramot:

 We have reviewed your amended draft registration statement and have the
following
comments.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. 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 the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 1 to Draft Registration Statement on Form S-1
Financial Statements
Consolidated Statements of Operations, page F-5

1. Please revise to separately present the amount of interest expense
incurred for each
 reporting period. Refer to Rule 5-03(b)(8) of Regulation S-X.
Consolidated Statements of Convertible Preferred Stock and Stockholders'
Deficit, page F-7

2. Please consider clearly delineating your convertible preferred stock
that is classified
 outside of stockholders deficit from your stockholders deficit by
using a black line
 separating these balances. Refer to 480-10-S99-1.
 June 17, 2025
Page 2

 Please contact Laura Veator at 202-551-3716 or Stephen Krikorian at
202-551-3488 if
you have questions regarding comments on the financial statements and related
matters. Please contact Mariam Mansaray at 202-551-5176 or Jan Woo at
202-551-3453 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Ryan J. Dzierniejko
</TEXT>
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<TEXT>
 May 13, 2025

Daniel Ramot
Chief Executive Officer
Via Transportation, Inc.
114 5 th Ave, 17 th Floor
New York, NY 10011

 Re: Via Transportation, Inc.
 Draft Registration Statement on Form S-1
 Submitted April 15, 2025
 CIK No. 0001603015
Dear Daniel Ramot:

 We have reviewed your draft registration statement and have the
following comments.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. 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 the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-1
Cover Page

1. You state that the Chief Executive Officer and Chairman, Daniel Ramot,
will have
 control over most matters that require approval by your stockholders,
including the
 election of directors and approval of significant corporate
transactions. Here and
 elsewhere as appropriate, if true, please disclose that you will be
considered a
 "controlled company" following this offering under NYSE listing
standards, if true. If
 this is the case, please also disclose whether you intend to rely on the
exemptions to
 corporate governance requirements as a controlled company.
 May 13, 2025
Page 2
Prospectus Summary, page 1

2. We note that you attribute statements to "Third Party Market Data,"
including
 references to the report you commissioned from BCG. Please revise to
state the
 specific source of each statement.
Summary Consolidated Financial and Operating Information, page 19

3. Please provide a reconciliation of the weighted average number of shares
of common
 stock used in computing net loss per share to the weighted average
number of shares
 of common stock used in computing pro forma net loss per share, once
amounts are
 known. Describe each transaction and the number of shares included.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Factors Affecting Our Performance
Revenue Retention, page 82

4. We note your disclosure of dollar-based gross revenue retention for
government
 customers. Tell us how you considered also disclosing dollar-based gross
revenue
 retention for all customers.
Results of Operations
Comparison of the Years Ended December 31, 2023 and 2024
Revenue, page 87

5. Tell us how you considered disclosing the increase in Platform revenue
attributable to
 having a full year of CityMapper results in your financial statements
for the year
 ended December 31, 2024.
Certain Relationship and Related Party Transactions, page 143

6. Please disclose the parties to the Investors' Rights Agreement. We note
that you intend
 to terminate the rights under the current agreement and enter into a new
agreement
 that provides similar registration rights.
Consolidated Financial Statements
Notes to Consolidated Financial Statements
2. Significant Accounting Policies
Revenue Recognition
Revenue Arrangements, page F-15

7. Clarify how the transaction price is allocated among your subscription
services and
 professional services when these services are included in the same
contract with
 customers. Refer to ASC 606-10-32-31 through 32-35. Further, tell us
what
 consideration you gave to separately disclosing professional services,
if material.
Remaining Performance Obligations, page F-16

8. Please revise your disclosures to clarify how the anticipated number of
driver hours
 and service hours is determined in your estimation of variable revenue.
That is, clarify
 whether these estimates are based on historical volumes used by
customers or some
 other manner, and clarify what you mean by stipulated in the
contract. Refer to ASC
 606-10-32-8 and 32-9.
 May 13, 2025
Page 3

15. Stockholders' Deficit, page F-32

9. When your preliminary IPO price is known, please provide us with a
breakdown of all
 equity awards granted from six month before the date of this letter and
leading up to
 the preliminary pricing of your IPO. This breakdown should list grants
in chorological
 order including the fair value of the underlying common stock used to
value such
 awards as determined by your board of directors. Please reconcile and
explain the
 differences between the fair values of the underlying equity interest
determined on
 each grant date, including the difference between the most recent grant
date fair value
 and the midpoint of your offering range. In addition, your disclosure
should fully
 describe the assumptions utilized at the IPO valuation date that are
significantly
 different than those used in the most recent valuation.
General

10. Please supplementally provide us with copies of all written
communications, as
 defined in Rule 405 under the Securities Act, that you, or anyone
authorized to do so
 on your behalf, present to potential investors in reliance on Section
5(d) of the
 Securities Act, whether or not they retain copies of the communications.
11. Many of your tables and graphics include print that is not legible. For
example, your
 graphic on page 116 contains text that is too small to be legible.
Please revise
 your graphics throughout your prospectus as applicable to ensure that
the text is
 legible.
 Please contact Laura Veator at 202-551-3716 or Stephen Krikorian at
202-551-3488 if
you have questions regarding comments on the financial statements and related
matters. Please contact Mariam Mansaray at 202-551-6356 or Jan Woo at
202-551-3453 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Ryan J. Dzierniejko
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