On behalf of our client, Ibotta, Inc. (the “Company”), we submit this letter in response to the comments contained in the letter dated March 28, 2024 (the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission relating to the above referenced Registration Statement on Form S-1 as filed by the Company on March 22, 2024. We are concurrently filing via EDGAR this letter and a Form S-1 (the “Form S-1”).

1.We note the amendment at the end of this risk factor, and in other risk factors, describing that downturns and store closures at publishers have and could pose a risk to your business. However, the title of this risk factor addresses the risk associated with maintaining and expanding your relationships with publishers. If downturns and store closures at publishers poses a material risk to your business, please either prepare a new risk factor describing that risk or update the risk factor heading of this risk factor to better describe the contents.

2.In order to help investors assess the disclosure, please name the CPG client for whom your assistance helped them increase their market share from 30% to 40%.

3.We note you no longer reference Dollar General as your client that is also the leader in market share for the "dollar" sector. Please name the dollar sector market leader that has chosen Ibotta to deploy their rewards program.

4.We note here, and throughout the registration statement, that references to Dollar General have been removed. Please tell us why the relationship no longer appears in your registration statement, as it previously appeared to be a material part of your business. In this regard, we note your relationship with Dollar General still features on your website.