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December 5, 2023
Christina Schwartz
Interim Chief Financial Officer
Opendoor Technologies Inc.
410 N. Scottsdale Road, Suite 1600
Tempe, AZ 85288
Re:Opendoor Technologies Inc.
Form 10-K for the year ended December 31, 2022
Form 10-Q for the quarterly period ended September 30, 2023
File No. 001-39253
Dear Christina Schwartz:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the year ended December 31, 2022
Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Financial Highlights, page 40
1.Please revise future filings both here and throughout your filing, as applicable, to label all
non-GAAP measures as such and to provide a cross-reference to your discussion and
reconciliations of such non-GAAP measures to their nearest comparable GAAP
measures.
Inventory Management, page 42
2.Given the significance of sell-through rates, holding periods and portfolio aging to your
business, please tell us what consideration you have given to disclosing these metrics in a
format, such as a tabular presentation, that would enable a reader to see how movements
between each of these metrics impacted your business in each of the periods presented.
For instance, we note your discussion on page 30 of the effects that aging of the portfolio

 FirstName LastNameChristina Schwartz
 Comapany NameOpendoor Technologies Inc.
 December 5, 2023 Page 2
 FirstName LastName
Christina Schwartz
Opendoor Technologies Inc.
December 5, 2023
Page 2
has on your ability to finance homes; however, it is not readily apparent what effect
portfolio aging had on your ability to finance homes and on cash as collateral in the
periods presented.
Adjusted EBIDTA Margin , page 46
3.Please revise future filings to disclose how you calculate adjusted EBITDA margin.
Form 10-Q for the quarterly period ended September 30, 2023
Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Overview, page 41
4.Please tell us what consideration you gave to enhancing your disclosure regarding the
nature of your increase in restricted cash during the period, including but not limited to the
amount of the increase that relates to the requirement to pledge additional cash as
collateral for properties you have owned for extended periods. In addition, we note your
disclosure on page 41 that states, "[t]he increase in our restricted cash balance of $570
million as compared to December 31, 2022 was a result of the proactive reduction of our
acquisition pace via higher spreads embedded in our offers and lower marketing
investment, resulting in greater restricted cash available for the future acquisition of real
estate inventory." Please clarify for us how this assertion is representative of the increase
in restricted cash during the period.
            In closing, 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
absence of action by the staff.
            Please contact Paul Cline at 202-551-3851 or Jennifer Monick at 202-551-3295 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction