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                 February 9, 2022

       Jason Wilk
       Chief Executive Officer
       Dave Inc.
       750 N. San Vicente Blvd.
       900W West Hollywood, CA 90069

                                                        Re: Dave Inc.
Statement on Form S-1
                                                            Filed February 2,
                                                            File No. 333-262478

       Dear Mr. Wilk:

              This is to advise you that we have not reviewed and will not
review your registration

               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 David Lin, Staff Attorney, at (202) 551-3552 or
Sandra Hunter
       Berkheimer, Legal Branch Chief, at (202) 551-3758 with any questions.


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