SecProbe.io

Mail Stop 4631
December 1 , 2017

Via E -Mail
Paul Zepf
Chief Executive Officer
Global Partner Acquisition Corp.
1 Rockefeller Plaza, 11th Floor
New York, New York  10020

Re: Global Partner Acquisition Corp.
 Preliminary Proxy Statement on Schedule 14A
Filed November 6, 2017
Form 10 -Q for Fiscal Quarter Ended September 30, 2017
Filed November 9, 2017
File No. 001 -37523

Dear Mr. Zepf :

We have reviewed your filing an d have the following 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response and any amendment you may file in response to these
comments , we may have  additional comments.

General

1. Please note the updating requirements for the financial statements and related disclosures
pursuant to Rule 3 -12 of Regulation S -X.

2. Please provide an analysis addressing whether each of the following issuances should be
registered under the Securities Act of 1933:

 Class B common  stock that Purple Innovation, Inc. will issue to InnoH old;
 Class B Units that Purple Innovation, LLC will issue to  InnoH old;
 Class A Units that Purple Innovation, LLC will issue to GPAC.

Paul Zepf
Global Partner Acquisition Corp.
December 1 , 2017
Page 2

 3. Please explain whether the “renaming” of the existing GPAC common s tock Class A
common stock of Purple Innovation, Inc. constitutes a reclassification of securities and
provide an analysis addressing whether you are required to register the reclassification
under the Securities Act of 1933.

Letter to the Stockholders

4. Please revisit the disclosure relating to the changes to the corporate structure so that you
provide shareholders with a clear, concise, and understandable discussion of the
corporate reorganization taking place in connection with this transaction.  It is no t until
page 122 that shareholders learn that the business combination involves the creation of an
Up-C structure and, even there, you have not provided materially complete disclosure of
the steps associated with the creation of the Up -C, why you have chos en it, and how it
impacts current and future shareholders.  Although you make a passing reference to
“Class A Units” in the second bullet here, you fail to provide any contextual disclosure
about the significance of those membership units to the overall co rporate structure.
Please revise  throughout .

Summary of the Proxy Statement and Business Combination, page 1

Reasons for the Business Combination, page 6

5. We note disclosure of Purple’s “annualized net revenue” here and on pages 17 and 109.
Please also disclose th e actual net revenue to date in these sections.

Board of Directors of the Company Following the Business Combination, page 9

6. Please disclose the names of the two other persons who will serve on the board of
directors following the business combination.

Risk Factors, page 39

7. You disclose on page 70 that the payments you expect to make under the Tax Receivable
Agreement will be substantial and could have a material adverse effect on your financial
condition.  Please discuss the range of future payments th at you expect to pay InnoHold
under the agreement including the scenario when the early termination provisions
contained in the agreement are triggered.  Please expand your liquidity discussion in
MD&A to discuss the negative effects of these payouts.  Als o explain how you
considered disclosure of the potential impact on future earnings associated with this
contingency in your pro forma presentation.

8. We note that in proposal five, your amended and restated certificate of incorporation will
include an exclu sive forum provision.  Please include a risk factor to discuss the effects
of such a provision on your stockholders, including the possibility that the exclusive

Paul Zepf
Global Partner Acquisition Corp.
December 1 , 2017
Page 3

 forum provision may discourage stockholder lawsuits, or limit stockholders’ ability to
obtain a favorable judicial forum for disputes with the company, its officers and directors.

We have identified material weaknesses . . ., page 58

9. We note that your independent registered public accounting firm identified certain
material weaknesses in your internal control over financial reporting.   Please disclose the
dollar amounts relating to the post -closing adjustments that were made to the company´s
books and records and your financial statements as a result of the material weaknesses.

Unaudited Pro F orma Condensed Combined Financial Information , Page 75

10. You disclose that the pro forma financial information for the six months ended June 30,
2017 gives effect to the business combination as if it occurred on January 1, 2017.  Please
revise to present th e transaction assuming it occurred at the beginning of the fiscal year
presented and carried forward through any interim period presented.  Refer to Rule 11 -
02(b) of the Regulation S -X.

11. Your pro forma presentation assumes two different levels of redemptio ns.  You disclose
on pages 36 and 76 that one of the assumed redemption levels was 1,000,000 shares
which is the maximum number of shares redeemable that would allow you to maintain at
least $100.0 of net parent cash in the trust account in order to close the business
combination.  However, we note from the table on page 5 and your disclosure on page 27
that you also assume a maximum redemption of 1,050,511 shares.  Please revise to
ensure your maximum redemption assumption is consistent throughout the docu ment.

12. We note from your disclosure on page 82 that the merger consideration is calculated
based on Purple’s agreed upon enterprise value of $900 million.  Please discuss in detail
how you determined the enterprise value of Purple.

13. The footnote references  for the pro forma income statement adjustments on page 78 do
not appear to correspond to the footnotes on page 83.  In addition, the cross reference
included in footnote 3(c) related to the non -controlling interest on page 82 does not
appear to be correct ly referenced.  Please advise or revise accordingly.

Comparative Share Information, Page 85

14. The pro forma basic and diluted EPS amounts for the year ended December 31, 2016
presented in this table are not consistent with amounts presented in the pro form a income
statement on page 79.  Please advise or revise accordingly.

Paul Zepf
Global Partner Acquisition Corp.
December 1 , 2017
Page 4

 Purple Management’s Discussion and Analysis, Page 183

15. We note from your disclosure that the significant increases in total net revenue both for
the six months ended June 30, 2017 and the year ended December 31, 2016 were
primarily due to higher sales of mattresses.  Please revise to further discuss the extent  to
which increases in the sales were attributable to changes in price or volume, and the
underlying drivers of those changes.  Refer to Item 303(a) of Regulation S -K.

16. Please discuss in detail the impact of the EquaPressure acquisition on your results of
operations and financial condition.

17. Your discussion of changes in operating cash flows  between comparable periods  on page
191 is a recitation of  information found on the statements of cash flow.  Please revise to
provide a more complete discussion address ing the material drivers underlying significant
changes of individual cash flow items (e.g., inventory and accounts receivable).  Refer to
Section IV.B.1 of SEC Release 33 -8350.

Purple Financial Statements

Note 8 – Concentrations, Page F -40

18. Please revis e to provide  the revenue by product disclosure as contemplated by ASC 280 -
10-50-40, similar to the disclosure  that you provide  on page F -62.

Note 10 – Subsequent Events, Page F -41

19. Please revise your footnote to disclose the date through which subsequent events have
been evaluated and whether that date represents the date the financial statements were
issued or the date they were available to be issued.  Refer to ASC 855 -10-50-1.

Form of Proxy

20. Please explain the purpose for requiring written notice to th e transfer agent in order to
perfect the request for redemption.  At a minimum, in order to make it easier for
shareholders to comply with the requirement for the written demand that you redeem
their shares, you should provide shareholders with an automate d process that helps them
comply with the condition you are imposing .  Please advise.

21. Please ensure that the proxy card is marked as “preliminary” until the time that you file a
definitive proxy statement.  Refer to Rule 14a -6(e)(1) of the Exchange Act.

22. Please revise to state whether any matters are conditioned on the approval of other
matters.  Refer to Rule 14a -4(a)(3) of the Exchange Act.

Paul Zepf
Global Partner Acquisition Corp.
December 1 , 2017
Page 5

 Form 10 -Q for the Quarter Ended September 30, 2017

Exhibits 31.1 and 31.2

23. We note that the certifications do not include the reference to internal control over
financial reporting in the introductory language in paragraph 4 as required by Item
601(b)(31) of Regulation S -K.  This comment also applies to your Forms 10 -Q for the
quarterly periods ended June 30, 2017 and  March 31, 2017.  Please revise future filing to
include the correct certifications.

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 abse nce of
action by the staff.

You may contact SiSi Cheng, Staff Accountant at (202) 551 -5004  or, in her absence,
John Cash, Accounting Branch Chief, at (202) 551 -3768  if you have questions regarding
comments on the financial statements and related matters .  Please contact Sherry Haywood, Staff
Attorney at (202) 551 -3345  or, in her absence,  me at (202) 551 -3397  with any other questions.

Sincerely,

 /s/ Jay Ingram

 Jay Ingram
Legal Branch Chief
Office of Manufacturing and
Construction

Cc: Via E -Mail
 Joshua Englard, Esq.