United States securities and exchange commission logo

                             March 24, 2021

       Ron Yekutiel
       Chairman and Chief Executive Officer
       Kaltura, Inc.
       250 Park Avenue South
       10th Floor
       New York, New York 10003

                                                        Re: Kaltura, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed March 23,
                                                            File No. 333-253699

       Dear Mr. Yekutiel:

             We have reviewed your amended registration statement and have the
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Amendment No. 1 to Form S-1

       Prospectus Summary, page 1

   1.                                                   Please provide a
summary of the transactions with the Special Situations Investing Group
                                                        II, LLC, an affiliate
of Goldman Sachs & Co., in connection with this offering. In this
                                                        regard, discuss the
terms of the GS Warrant, the conversion of the Series F
                                                        convertible preferred
stock, and certain cash payments that you will be required to make if
                                                        the actual initial
public offering price is less than or equal to the midpoint of the price
                                                        range. Further, tell us
whether you are required to have a qualified independent
                                                        underwrtier in
accordance with FINRA Rule 5121 as a result of these transactions.
 Ron Yekutiel
Kaltura, Inc.
March 24, 2021
Page 2

        You may contact David Edgar, Staff Accountant, at (202) 551-3459 or
Christine Dietz,
Senior Staff Accountant, at (202) 551-3408 if you have questions regarding
comments on the
financial statements and related matters. Please contact Jan Woo, Legal Branch
Chief, at (202)
551-3453 with any other questions.

FirstName LastNameRon Yekutiel
                                                           Division of
Corporation Finance
Comapany NameKaltura, Inc.
                                                           Office of Technology
March 24, 2021 Page 2
cc:       Benjamin J. Cohen
FirstName LastName