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                                                              November 4, 2024

Ara Mahdessian
Chief Executive Officer
ServiceTitan, Inc.
800 N. Brand Blvd
Suite 100
Glendale, CA 91203

       Re: ServiceTitan, Inc.
           Amendment No. 4 to Draft Registration Statement on Form S-1
           Submitted October 22, 2024
           CIK No. 0001638826
Dear Ara Mahdessian:

     We have reviewed your amended draft registration statement and have the
following
comments.

       Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. 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 the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 4 to Draft Registration Statement on Form S-1
Prospectus Summary, page 1

1.     We note your revised disclosure that your net dollar retention rate has
declined
       slightly over the last ten fiscal quarters. Given your prominent
disclosure throughout
       the filing that your net dollar retention rate and gross dollar
retention rate is evidence
       of your ability to retain and expand customers, please provide balanced
disclosure by
       providing appropriate context regarding the decrease in your net
retention rate and/or
       gross retention rate. Disclose the amount of the decrease in rates over
the period.
       Clarify whether management uses the annual net dollar retention rate and
gross dollar
       retention rate to evaluate the company's business.
 November 4, 2024
Page 2

Notes to Condensed Consolidated Financial Statements
14. Subsequent Events, page F-73

2.    You disclose the following:

             Between July 31, 2024 and September 9, 2024, the Company granted
245,653
           RSUs vesting over four years and subject to service-only conditions.
             Between September 10, 2024 and October 21, 2024, the Company
granted 51,674
           RSUs vesting over four years and subject to service-only conditions.
             Additionally, in October 2024, the Company granted each of Ara
Mahdessian and
           Vahe Kuzoyan an award of 3,241,544 performance-based RSUs.

      Please revise your subsequent events disclosure beginning on page F-74 to
disclose
      the expected financial impact of the awards (i.e. unrecognized
compensation expense)
      pursuant to ASC 855-10-50-2(b). In addition, please tell us the grant
date fair value of
      the shares of common stock used to determine the amount of compensation
expense
      attributable to each of these grants. Please reconcile and explain the
differences
      between the fair values of a share of common stock determined on each
grant date
      including the difference between the most recent grant date fair value
and the
      midpoint of your offering range.
General

3.    Please provide balanced disclosure in the graphics in the forepart of the
registration
      statement. Please also disclose the net loss for each period that you
discuss revenue
      and revenue growth.
        Please contact Amanda Kim at 202-551-3241 or Stephen Krikorian at
202-551-3488
if you have questions regarding comments on the financial statements and
related
matters. Please contact Marion Graham at 202-551-6521 or Jan Woo at
202-551-3453 with
any other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Technology
cc:   Phillip Stoup
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