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                650 Town Center Drive, 20th Floor  Costa Mesa, California  92626-1925  Tel: +1.714.540.1235  Fax: +1.714.755.8290  www.lw.com  FIRM / AFFILIATE OFFICES  Beijing Moscow  Boston Munich  Brussels New York  Century City Orange County  Chicago Paris  Dubai Riyadh  Düsseldorf San Diego  Frankfurt San Francisco  Hamburg Seoul  Hong Kong Shanghai  Houston Silicon Valley  London Singapore  Los Angeles Tokyo  Madrid Washington, D.C.  Milan       June 17, 2021    VIA EDGAR   Securities and Exchange Commission  Division of Corporation Finance  100 F. Street, N.E.  Washington, D.C. 20549  Attention:  Irene Barberena-Meissner  Re: Virgin Galactic Holdings, Inc.  Registration Statement on Form S-3  Filed May 28, 2021  File No. 333-256607  Ladies and Gentlemen:  On behalf of Virgin Galactic Holdings, Inc. (the “Company”), we are submitting this letter to the  Securities and Exchange Commission (the “SEC”) via EDGAR in response to the comment letter from the  staff of the SEC (the “Staff”), dated June 16, 2021 (the “Comment Letter”), pertaining to the Company’s  above-referenced Registration Statement on Form S-3 (the “Registration Statement”). In connection with  such response, the Company is concurrently filing an amendment to the Registration Statement.  To assist your review, we have reproduced the text of the Staff’s comment in italics below, followed  by a response on behalf of the Company.  Registration Statement on Form S-3  General  1. It appears that you are seeking to register the issuance of shares of common stock underlying  2,666,667 warrants issued to investors in a private placement in connection with the closing of  your initial public offering. Please provide your analysis as to why you believe you are eligible to  register the issuance of the underlying common shares to private placement purchasers as these  shares appear to have been offered privately. Alternatively, please revise your registration fee table  and prospectus to indicate that the registration statement does not cover the offer and sale of these  underlying securities. For guidance, refer to Securities Act Sections Compliance and Disclosure  Interpretations 239.15 and 103.04.

June 17, 2021  Page 2    Response to Comment 1:  The Company advises the Staff that it has revised the Registration Statement to remove the issuance  of shares of common stock underlying warrants.  We hope that the foregoing has been responsive to the Staff’s comment. If you have any questions  or comments about this letter or need any further information, please call the undersigned at (714) 755-8008.  Best regards,  /s/ Drew Capurro  Drew Capurro  of LATHAM & WATKINS LLP    cc: Michael Colglazier, Virgin Galactic Holdings, Inc.  Michelle Kley, Virgin Galactic Holdings, Inc.  Justin G. Hamill, Latham & Watkins LLP