September 16, 2024

Zaichang Ye
Chief Executive Officer
SunCar Technology Group Inc.
c/o Shanghai Feiyou Trading Co., Ltd.
Suite 209, No. 656 Lingshi Road
Jing   an District, Shanghai, 200072
People   s Republic of China

       Re: SunCar Technology Group Inc.
           Form 20-F for Fiscal Year Ended December 31, 2023
           File No. 1-41706
Dear Zaichang Ye:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 20-F for Fiscal Year Ended December 31, 2023
Results of Operations
Year ended December 31, 2023 compared with year ended December 31, 2022
Adjusted EBITDA, page 77

1.     You provide enhanced discussion regarding your non-GAAP measure of
Adjusted
       EBITDA without providing similar discussion of the comparable GAAP
measure. When
       presenting and discussing non-GAAP measures, please ensure the
comparable GAAP
       measures are presented and discussed with equal or greater prominence.
Refer to Item
       10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the Non-GAAP
Financial
       Measures Compliance & Disclosure Interpretations.
Non-GAAP Financial Measures
Adjusted EBITDA, page 79

2.     Please revise your non-GAAP reconciliation of Adjusted EBITDA so that it
is reconciled
 September 16, 2024
Page 2

       to the most directly comparable GAAP measure (i.e. net loss). Also,
present the most
       directly comparable GAAP measure (i.e. net loss margin) to Adjusted
EBITDA margin.
       Refer to Item 10(e)(1)(i) of Regulation S-K and Questions 103.02 and
102.10 of the Non-
       GAAP Financial Measures Compliance & Disclosure Interpretations.
       In closing, 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 Ta Tanisha Meadows at 202-551-3322 or Joel Parker at
202-551-3651
with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Trade &
Services
cc:   Elizabeth Fei Chen, Esq.