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May 27, 2020

Via EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-3720

 Attention: Kathleen Collins, Accounting Branch Chief

Joyce Sweeney, Staff Accountant

 Re: Grid Dynamics Holdings, Inc.

Form 10-Q for the Quarterly Period Ended March 31, 2020

Filed May 11, 2020

File No 001-38685

Ladies and Gentlemen:

Grid Dynamics Holdings, Inc. (the “Company”),
submits this letter in response to comments from the staff (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) received by letter dated May 19, 2020, relating to the Company’s Form 10-Q for the quarterly
period ended March 31, 2020 filed with the Commission on May 11, 2020 (the “Form 10-Q”).

In this letter, we have recited the comment
from the Staff in italicized, bold type and have followed the comment with the Company’s response.

Form 10-Q for the Quarterly Period
Ended March 31, 2020

Item 4. Controls and Procedures; Evaluation
of Disclosure Controls and Procedures, page 25

 1. Please explain to us how you determined that your disclosure controls
and procedures (DCP) were effective, particularly considering you have identified an unremediated material weakness related to
lack of sufficient resources with appropriate depth and experience to interpret complex accounting guidance and prepare financial
statements and related disclosures in accordance with GAAP. In this regard, DCPs often include those components of internal control
over financial reporting (ICFR) which provide reasonable assurance that transactions are recorded as necessary to permit the preparation
of financial statements in accordance with GAAP. While we acknowledge that you have not yet been required to conduct an evaluation
of ICFR, please tell us how you determined that the material weakness you identified would not be considered a component of ICFR
that is also included in disclosure controls and procedures. We refer you to Sections II.D and E of SEC Release 33-8238 available
on our website at: https://www.sec.gov/rules/final/33-8238.htm#iid.

RESPONSE TO COMMENT
1:

The Company respectfully
advises the Staff that it has determined to revise the disclosure in Item 4 to read as follows and to file an amendment to the
Form 10-Q with the revised disclosure:

Securities and Exchange Commission

May 27, 2020

Page 2

Item 4. Controls and Procedures

Evaluation of Disclosure
Controls and Procedures

We previously
disclosed a material weakness in our internal control over financial reporting that remains unremediated. A material weakness is
defined as a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable
possibility that a material misstatement of Grid Dynamics’ financial statements will not be prevented or detected on a timely
basis. Subsequent to the original issuance of the private company financial statements for the year ended December 31, 2018,
we identified balances that were accounted for or presented incorrectly under GAAP relating to stock-based compensation, and the
presentation of retention bonuses and depreciation on the consolidated statement of income and comprehensive income.

The material
weakness identified was a lack of sufficient resources with appropriate depth and experience to interpret complex accounting guidance
and prepare financial statements and related disclosures in accordance with GAAP.

Grid Dynamics
was not required to perform an evaluation of internal control over financial reporting as of December 31, 2019, 2018, and
2017 in accordance with the provisions of the Sarbanes-Oxley Act as it was then a private company. Had such an evaluation been
performed, additional control deficiencies may have been identified by Grid Dynamics’ management, and those control deficiencies
could have also represented one or more material weaknesses.

An evaluation
was conducted under the supervision and with the participation of management, including our Chief Executive Officer (“CEO”)
and Chief Financial Officer (“CFO”), of the effectiveness of our disclosure controls and procedures (as defined in
Exchange Act Rules 13a-15(e) and Exchange Act Rules 15d-15(e)) as of March 31, 2020. Based on that evaluation, the CEO and CFO
concluded that our disclosure controls and procedures were not effective at the reasonable assurance level as of such date because
of the material weakness.

Grid Dynamics
has taken steps to enhance its internal control environment, including hiring a new Chief Financial Officer in December 2019, hiring
a Global Controller, and initiating a search to hire additional qualified accounting and financial reporting personnel. Additionally,
Grid Dynamics is implementing a new ERP system, which it believes will enhance its internal control over financial reporting. Once
all key hires in the finance function are in place, Grid Dynamics also plans to take additional steps to remediate the material
weakness by integrating them into its process of implementing and enhancing key controls over financial reporting and conducting
technical accounting training of key financial and accounting staff members involved in preparation and review of financial reporting
and interpretation of technical accounting guidance. Although Grid Dynamics plans to complete this remediation process as quickly
as possible, Grid Dynamics cannot at this time estimate how long it will take.

Grid Dynamics
has discussed the matters above with its Audit Committee, including the evaluation of disclosure controls and procedures, the material
weakness, and the steps it is taking to remediate the material weakness.

Internal Control Over
Financial Reporting

Our management,
including the CEO and CFO, confirmed there were no changes in our internal control over financial reporting during the three months
ended March 31, 2020 that have materially affected, or are reasonably likely to materially affect, our internal control over financial
reporting.

Inherent Limitations on
Effectiveness of Controls

Our management,
including our CEO and CFO, do not expect that our disclosure controls or our internal control over financial reporting will prevent
all errors and all fraud. A control system, no matter how well conceived and operated, can provide only reasonable, not absolute,
assurance that the objectives of the control system are met. Further, the design of a control system must reflect the fact that
there are resource constraints, and the benefits of controls must be considered relative to their costs. Because of the inherent
limitations in all control systems, no evaluation of controls can provide absolute assurance that all control issues and instances
of fraud, if any, have been detected. These inherent limitations include the realities that judgments in decision-making can be
faulty, and that breakdowns can occur because of a simple error or mistake. Additionally, controls can be circumvented by the individual
acts of some persons, by collusion of two or more people or by management override of the controls. The design of any system of
controls is also based in part upon certain assumptions about the likelihood of future events, and there can be no assurance that
any design will succeed in achieving its stated goals under all potential future conditions; over time, controls may become inadequate
because of changes in conditions, or the degree of compliance with policies or procedures may deteriorate. Because of the inherent
limitations in a cost-effective control system, misstatements due to error or fraud may occur and not be detected.

*********************************

Securities and Exchange Commission

May 27, 2020

Page 3

Please contact the undersigned if you have
any questions with respect to this response. Thank you for your assistance.

    Very truly yours,

    Grid Dynamics Holdings, Inc.

    /s/ Anil Doradla

    Anil Doradla

    Chief Financial Officer

    (Principal Financial and Accounting Officer)

 cc: Leonard Livschitz

Grid Dynamics Holdings, Inc.

Katharine A. Martin

Richard C. Blake

Wilson Sonsini Goodrich & Rosati,
P.C.

Rimma Tabakh

Grant Thornton LLP