November 5, 2024

Tian Gao
Vice President
Pony AI Inc.
1301 Pearl Development Building
1 Mingzhu 1st Street, Hengli Town, Nansha District,
Guangzhou, People   s Republic of China, 511458

        Re: Pony AI Inc.
            Registration Statement on Form F-1
            Filed October 17, 2024
            File No. 333-282700
Dear Tian Gao:

        We have reviewed your amended 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. Unless
we note
otherwise, any references to prior comments are to comments in our October 7,
2024 letter.

Form F-1 filed October 17, 2024
Risk Factors
"The current tensions in international trade and rising political tensions,
particularly between
the United States and China...", page 64

1.     We note your revised disclosure in response to our prior comment 8
regarding the
       U.S. Commerce Department's proposed ban on the sale of connected and
autonomous
       vehicles in the U.S. that are equipped with Chinese software and
hardware. Please
       further revise your risk factor to clarify whether and how the proposed
rulemaking, if
       finalized as proposed, would materially impact your current business and
operations
       in the U.S., including your research and development activities and road
testing, as
       well as any potential future imports or sales into the U.S. market of
connected
       vehicles using your technology.
 November 5, 2024
Page 2

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 109

2.    We note your response to prior comment 7. Please clarify your licensing
and
      applications revenues discussion on page 112 by quantifying the increases
of your
      various services and products, or by quantifying the increases and
presenting the total
      revenues for all the various products and services, such as POV
intelligent solutions,
      value-added technological services and V2X (vehicle-to-everything).
        Please contact Joseph Cascarano at 202-551-3376 or Robert Littlepage at
202-551-
3361 if you have questions regarding comments on the financial statements and
related
matters. Please contact Mariam Mansaray at 202-551-6356 or Matthew Crispino at
202-551-
3456 with any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Technology
cc:   Hi Le