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    Graubard Miller

                                                                                The Chrysler Building

                                                                                405 Lexington Avenue

                                                                                New York, N.Y. 10174-1101

                                                                                (212) 818-8800

    facsimile

    direct dial number

    (212) 818-8881

    (212) 818-8638

    email address

    jgallant@graubard.com

May
13, 2019

Division
of Corporation Finance

Office
of Manufacturing and Construction

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

 Re: Capitol
Investment Corp. IV

Registration
Statement on Form S-4

Submitted
April 11, 2019

CIK No. 333-230817

Ladies
and Gentlemen:

On
behalf of Capitol Investment Corp. IV (“Capitol” or the “Company”), we respond as follows to the Staff’s
comment letter, dated May 8, 2019, relating to the above-captioned Registration Statement on Form S-4 (“Registration Statement”).
Captions and page references herein correspond to those set forth in Amendment No. 1 to the Registration Statement (“Amendment
No. 1”), a copy of which has been marked with the changes from the original filing of the Registration Statement. All references
to page numbers, captions and annexes correspond to Amendment No. 1 unless otherwise specified.

Please
note that for the Staff’s convenience, we have recited each of the Staff’s comments and provided the Company’s
response to each comment immediately thereafter.

Form
S-4 Filed April 11, 2019

General,
page i

 1. We
                                         note that your forum selection provision identifies the Court of Chancery of the State
                                         of Delaware as the exclusive forum for certain litigation, including any “derivative
                                         action.” Please disclose whether this provision applies to actions arising under
                                         the Securities Act or Exchange Act. In that regard, we note that Section 27 of the Exchange
                                         Act creates exclusive federal jurisdiction over all suits brought to enforce any duty
                                         or liability created by the Exchange Act or the rules and regulations thereunder, and
                                         Section 22 of the Securities Act creates concurrent jurisdiction for federal and state
                                         courts over all suits brought to enforce any duty or liability created by the Securities
                                         Act or the rules and regulations thereunder. If the provision applies to Securities Act
                                         claims, please also revise your prospectus to state that there is uncertainty as to whether
                                         a court would enforce such provision and that stockholders will not be deemed to have
                                         waived the company’s compliance with the federal securities laws and the rules
                                         and regulations thereunder. If this provision does not apply to actions arising under
                                         the Securities Act or Exchange Act, please also ensure that the exclusive forum provision
                                         in the governing documents states this clearly.

We
have revised the form of certificate of incorporation to provide that with respect to stockholder claims over which the Court
of Chancery of the State of Delaware does not have jurisdiction (including the Exchange Act), the federal district court for the
District of Delaware or other state courts of the State of Delaware shall be the exclusive forum for certain litigation, including
any “derivative action.”

Securities and Exchange Commission

May 13, 2019

Page 2

We
have also revised the disclosure regarding the forum selection on pages 91 and 167 and page B-3 of Annex B to reflect this change
and address the requests in the Staff’s comment above, including to clarify that the exclusive forum provision, as revised,
applies to stockholder claims under the Securities Act and the Exchange Act..

 2. We
                                         note that you have an exclusive forum provision in your bylaws that identifies the Court
                                         of Chancery of the State of Delaware (or, in the event that the Chancery Court does not
                                         have jurisdiction, the federal district court for the District of Delaware or other state
                                         courts of the State of Delaware) and a separate exclusive forum provision in your certificate
                                         of incorporation that identifies Court of Chancery of the State of Delaware as the exclusive
                                         forum. Please discuss how the exclusive forum provision in your bylaws is intended to
                                         operate given the exclusive forum provision in your certificate of incorporation. Please
                                         ensure that your disclosures are consistent with your exclusive forum provisions.

We
have removed the forum selection provision from the form of bylaws on page B-24 of Annex B and have revised the certificate of
incorporation as set forth in our response to comment 1 above. Accordingly, we respectfully submit that there is no longer a need
to discuss how the provisions between the certificate of incorporation and bylaws are intended to operate.

 3. Please
                                         confirm that the newly created Delaware entity will: (i) file a post-effective amendment
                                         to this registration statement expressly adopting the such statements as its own registration
                                         statement for all purposes of the Securities Act of 1933 and the Securities Exchange
                                         Act of 1934 and (ii) such amendment will become effective before securities governed
                                         by Delaware law are exchanged for securities governed by Cayman law. Refer generally
                                         to Securities Act Rule 414 and Securities Act Rules C&D 611.03.

We
hereby confirm that the newly created Delaware entity will (i) file a post-effective amendment to the Registration Statement expressly
adopting it as its own registration statement for all purposes of the Securities Act of 1933, as amended, and the Securities Exchange
Act of 1934, as amended, and (ii) such amendment will become effective before securities governed by Delaware law are exchanged
for securities governed by Cayman law.

Securities and Exchange Commission

May 13, 2019

Page 3

Comparative
Per Share Data, page 22

 4. Please
                                         disclose, if true, that separate equivalent pro forma per share data amounts have not
                                         been presented given that there is a 1 to 1 share exchange ratio between Nesco and Capitol.

We
have revised the disclosure on page 22 of the Registration Statement as requested to include the exchange ratio between Nesco
and the Company and the equivalent pro forma per share data amounts.

Anticipated
Accounting Treatment, page 66

 5. You
                                         have determined that the merger between the Capitol and Nesco entities will be accounted
                                         for as a reverse merger with Nesco being the accounting acquirer. Please help us better
                                         understand how you made this determination pursuant to ASC 805-10-55-5 as well as ASC
                                         805-10-55-11 through 55-15. Please specifically address your consideration of the following
                                         as part of your response:

 ● Please
                                         address the relative voting rights in the combined entity after the business combination.
                                         Assuming no Capitol shareholders elect to redeem their shares for cash, Nesco shareholders
                                         will own only 26.6% of the outstanding shares of Capitol compared to Capitol shareholders
                                         owning 73.4%. If 14,135,936 ordinary shares are redeemed for cash, which assumes the
                                         maximum redemption of Capitol’s shares, Nesco shareholders will own 42.2% and Capitol
                                         shareholders will own 57.8% of the Capitol shares. Please also address your consideration
                                         of outstanding warrants. Refer to ASC 805-10-55-12(a); and

 ● Please
                                         address your consideration of the composition of the board of directors. Your disclosures
                                         on page 88 indicate that Nesco may designate only two of the seven board of directors.
                                         If Nesco beneficially owns 35% or more of the issued and outstanding shares, than Nesco
                                         will have the right to designate only three of the eight board of directors. Refer to
                                         ASC 805-10-55-12(c).

In
response to the Staff’s comment, we are providing Capitol’s and Nesco’s analysis of the factors set forth in
ASC 805-10-55-11 through 55-15 for determining which of the combining entities is the acquirer for accounting purposes.

Securities and Exchange Commission

May 13, 2019

Page 4

55-11
In a business combination effected primarily by transferring cash or other assets or by incurring liabilities, the acquirer usually
is the entity that transfers the cash or other assets or incurs the liabilities.

Capitol
and Nesco do not believe this transaction will be primarily effected by cash. Pursuant to the Merger Agreement, Nesco Owner will
receive $75.0 million in cash and 17,464,235 shares of common stock (approximate value of $179.2 million based on a $10.26 trading
price per share of the Company as of May 10, 2019) if there are no redemptions for cash, adjusted to zero cash and 24,964,235
shares of common stock assuming maximum redemptions for cash. Nesco Owner will also receive warrants to purchase 2,500,000 of
common stock. As such, Capitol and Nesco believe this factor is not applicable.

55-12
In a business combination effected primarily by exchanging equity interests, the acquirer usually is the entity that issues its
equity interests. However, in some business combinations, commonly called reverse acquisitions, the issuing entity is the acquiree.
Subtopic 805-40 provides guidance on accounting for reverse acquisitions. Other pertinent facts and circumstances also shall be
considered in identifying the acquirer in a business combination effected by exchanging equity interests, including the following:

(a)
The relative voting rights in the combined entity after the business combination. The acquirer usually is the combining entity
whose owners as a group retain or receive the largest portion of the voting rights in the combined entity. In determining which
group of owners retains or receives the largest portion of the voting rights, an entity shall consider the existence of any unusual
or special voting arrangements and options, warrants, or convertible securities.

Capitol
and Nesco believe that the transaction is being effected primarily by exchanging equity interests. As such, Capitol and Nesco
started their analysis by considering the anticipated relative voting rights immediately after the transaction. Capitol anticipates
that its shareholders on a combined basis will hold between approximately 73% of the combined entity if no shares are redeemed
and approximately 58% of the combined entity under the maximum redemption scenario. That is, the Nesco Owner and Nesco management
will hold between approximately 27% and approximately 42% on a combined basis. If one were to consider these percentages simplistically,
this factor seems to point toward Capitol being the accounting acquirer consistent with the interpretative guidance in Section
2.3 of PwC’s Business Combinations and Noncontrolling Interests (2018) publication (which is consistent with each
company’s understanding of guidance from other Big 4 Accounting firms as well), which states:

The
weight of relative voting rights in the combined entity after the business combination generally increases as the portion of the
voting rights held by the majority becomes more significant (e.g., split of 75% and 25% may be more determinative than a split
of 51% and 49%).

Securities and Exchange Commission

May 13, 2019

Page 5

However,
that interpretative guidance then goes on to say:

The
existence of a party with a large minority voting interest may be a factor in determining the acquirer. For example, a newly combined
entity’s ownership includes a single investor with a 40% ownership, while the remaining 60% ownership is held by a widely
dispersed group. The single investor that owns the 40% ownership in the combined entity is considered a large minority voting
interest.

Capitol
and Nesco therefore believe this factor must be considered in conjunction with the factor in ASC 805-10-55-12(b).

(b)
The existence of a large minority voting interest in the combined entity if no other owner or organized group of owners has a
significant voting interest. The acquirer usually is the combining entity whose single owner or organized group of owners holds
the largest minority voting interest in the combined entity.

Capitol
and Nesco believe that this factor indicates that entities should consider the underlying shareholder groups to determine if a
large minority voting interest exists when no one group of shareholders has obtained control over the combined entity. Immediately
after the transaction, the largest shareholder or group of shareholders will be the Nesco Owner and Nesco management with approximately
27% (in the no redemption scenario).

The
parties considered the other shareholder groups with anticipated significant ownership in the combined entity. The precombination
non-beneficial ownership of such shareholders is presented in the table below.

    Capitol Acquisition Management IV, LLC
      8 %

    Capitol Acquisition Founder IV, LLC
      4 %

    Alyeska Investment Group, LP
      4 %

    Polar Asset Management Partners Inc.
      3 %

Capitol
Acquisition Management IV, LLC and Capitol Acquisition Founder IV, LLC each have as their members two separate executive officers
of Capitol. There are no agreements between these two entities indicating that they will vote or make other shareholder decisions
together. However, if these entities were considered a group for purposes of this analysis, their combined ownership would not
exceed that of the Nesco Owner and Nesco management. Also, the current independent directors of the Company, who will resign from
the board in connection with the Transaction, will own a voting interest of approximately 0.2%, and the other shareholders are
unaffiliated to Capitol and are widely disbursed, and as a result not expected to vote in tandem.

Securities and Exchange Commission

May 13, 2019

Page 6

Capitol’s
warrants are not exercisable until 30 days after the close of the business combination and the parties determined that, if the
warrants are in the money and exercised at that time, they would not significantly alter the foregoing analysis.

As
such, and consistent with the PwC interpretative guidan