United States securities and exchange commission logo October 11, 2023 Gal Krubiner Chief Executive Officer Pagaya Technologies Ltd. 90 Park Ave New York, NY 10016 Re: Pagaya Technologies Ltd. Registration Statement on Form F-3 Filed October 4, 2023 File No. 333-274862 Dear Gal Krubiner: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Aisha Adegbuyi at 202-551-8754 with any questions. Sincerely, Division of Corporation Finance Office of Finance cc: John McKenna, Esq.