121 Derech Menachem Begin

Tel Aviv 6701203, Israel

December 2, 2022

 

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

RE:	Pagaya Technologies Ltd.
	Registration Statement on Form F-1
	File No. 333-266930
	Request for Acceleration of Effective Date

Requested Date:	December 6, 2022
Requested Time:	4:00 P.M. Eastern Time

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, the undersigned registrant (the “Registrant”) hereby requests that the U.S. Securities and Exchange Commission (the “Commission”) take appropriate action to cause the above-referenced Registration Statement on Form F-1 (the “Registration Statement”) to become effective on December 6, 2022, at 4:00 p.m., Eastern Time, or as soon thereafter as is practicable or at such later time as the Registrant may orally request via telephone call to the staff of the Commission. The Registrant hereby authorizes each of John T. McKenna and Natalie Y. Karam of Cooley LLP, counsel to the Registrant, to make such request on its behalf.

Once the Registration Statement has been declared effective, please orally confirm that event with John T. McKenna of Cooley LLP, counsel to the Registrant, at (650) 843-5059, or in his absence, Natalie Y. Karam at (650) 843-5778.

	Very truly yours,
	Pagaya Technologies Ltd.
	By:	/s/ Gal Krubiner
	Name:	Gal Krubiner
	Title:	Chief Executive Officer
	By:	/s/ Michael Kurlander
	Name:	Michael Kurlander
	Title:	Chief Financial Officer

cc:	Richmond Glasgow, Pagaya Technologies Ltd.
	John T. McKenna, Cooley LLP
	Rupa Briggs, Cooley LLP
	Natalie Y. Karam, Cooley LLP