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                            October 11, 2022

       Gal Krubiner
       Chief Executive Officer
       Pagaya Technologies Ltd.
       Azrieli Sarona Bldg, 54th Floor
       121 Derech Menachem Begin
       Tel-Aviv 6701203, Israel

                                                        Re: Pagaya Technologies
Ltd.
                                                            Amendment No. 2 to
Registration Statement on Form F-1
                                                            Filed October 3,
2022
                                                            File No. 333-266930

       Dear Gal Krubiner:

             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
September 20, 2022 letter.

       Amendment No. 2 to Registration Statement on Form F-1

       Unaudited Pro Forma Condensed Combined Balance Sheet, page 82

   1.                                                   We note Pagaya
consummated its previously announced business combination with EJFA
                                                        on June 22, 2022.
Please note that a pro forma balance sheet is not required when an
                                                        acquisition is already
reflected in a historical balance sheet. Revise your presentation
                                                        accordingly. Refer to
Regulation S-X 11-02 (a)(12)(c)(1).
   2.                                                   Please revise to
include a pro forma condensed combined statement of operations for the
                                                        interim period ending
June 30, 2022. Refer to Regulation S-X 11-02 (a)(12)(c)(2)(i).
 Gal Krubiner
FirstName LastNameGal
Pagaya Technologies Ltd.Krubiner
Comapany
October 11,NamePagaya
            2022       Technologies Ltd.
October
Page 2 11, 2022 Page 2
FirstName LastName
Index to Financial Statements, page F-1

3.       Please revise to include unaudited financial statements that include
footnotes for Pagaya
         Technologies Ltd. for the interim period ending June 30, 2022. Refer
to Item 8.A.5 of
         Form 20-F.
      Please contact Tonya K. Aldave at (202) 551-3601 or John Dana Brown at
(202) 551-
3859 with any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Finance
cc:      John T. McKenna, Esq.