SecProbe.io

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 January 21, 2026

VIA EDGAR

 Division of Corporation Finance

Office of Energy & Transportation

 United States
Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549-3628

 Attention: J. Elizabeth Packebusch

Re:
 Request for Effectiveness for Virgin Galactic Holdings, Inc.

Registration Statement on Form S-3 (File
No. 333-292647)

 Dear Ms. Packebusch:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Virgin Galactic Holdings, Inc. (the
“Registrant”) hereby respectfully requests that the effectiveness of the above-referenced Registration Statement be accelerated to 10:00 a.m. Eastern Time, on Friday, January 23, 2026, or as soon thereafter as practicable.
The Registrant respectfully requests that you notify David Ni of O’Melveny & Myers LLP of such effectiveness by telephone at (212) 326-2052.

If you have any questions or comments regarding the foregoing, please do not hesitate to contact Mr. Ni at the telephone number above.

Very truly yours,

Virgin Galactic Holdings, Inc.

By:

 /s/ Sarah Kim

Name:

Sarah Kim

Title:

Executive Vice President, Chief Legal Officer and Corporate Secretary

 cc: David Ni, O’Melveny & Myers LLP

January 15, 2026
Douglas Ahrens
Chief Financial Officer
Virgin Galactic Holdings, Inc
1700 Flight Way
Tustin, CA 92782
Re:Virgin Galactic Holdings, Inc
Registration Statement on Form S-3
Filed January 9, 2026
File No. 333-292647
Dear Douglas Ahrens:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Liz Packebusch at 202-551-8749 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:David Ni

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 Virgin Galactic Holdings, Inc.
 1700 Flight Way Tustin,
California 92782 January 2, 2026
 VIA EDGAR United States Securities and Exchange
Commission Division of Corporation Finance 100 F Street,
N.E. Washington, D.C. 20549-6010 Attention: Claudia Rios;
Dan Morris

 Re:
 Virgin Galactic Holdings, Inc.
 Registration Statement on Form S-3
 File No. 333-292017
 To the addressee set forth above: In accordance
with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-3
initially filed on December 9, 2025 (as amended, the “ Registration Statement ”) of Virgin Galactic Holdings, Inc. (the “ Company ”). We respectfully request that the Registration
Statement become effective as of 4:30 p.m. Eastern Time on January 6, 2026, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel,
Latham & Watkins LLP, by calling Drew Capurro at (714) 755-8008. Thank you for your
assistance in this matter.

 Sincerely,

 VIRGIN GALACTIC HOLDINGS, INC.

 By:

 /s/ Sarah Kim

 Sarah Kim

 Chief Legal Officer and Secretary

 cc:
 Michael Colglazier, Virgin Galactic Holdings, Inc.
 Douglas Ahrens, Virgin Galactic Holdings, Inc.
 Drew Capurro, Latham & Watkins LLP
 Kevin Reyes, Latham & Watkins LLP

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Virgin Galactic Holdings, Inc.

166 North Roadrunner Parkway, Suite 1C

Las Cruces, New Mexico 88011

June 25, 2021

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-6010

Attention:  Irene Barberena-Meissner; Kevin Dougherty

Re:  Virgin Galactic Holdings, Inc.

  Registration Statement on Form S-3, as amended

  File No. 333-256607

Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-3 initially filed on May 28, 2021 (as amended, the “Registration Statement”) of Virgin Galactic Holdings, Inc. (the “Company”).  We respectfully request that the Registration Statement become effective as of 4:00 p.m. Eastern Time on June 29, 2021, or as soon as practicable thereafter.  Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Drew Capurro at (714) 755-8008.

Thank you for your assistance in this matter.

Very truly yours,

VIRGIN GALACTIC HOLDINGS, INC.

By:  /s/ Michelle Kley

  Michelle Kley

  Executive Vice President,

  General Counsel and Secretary

cc:   Michael Colglazier, Virgin Galactic Holdings, Inc.

Drew Capurro, Latham & Watkins LLP

Justin G. Hamill, Latham & Watkins LLP

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spces-3ano1_secresponsel

                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

United States securities and exchange commission logo
June 16, 2021
Michelle Kley
Executive Vice President, General Counsel and Secretary
Virgin Galactic Holdings, Inc
166 North Roadrunner Parkway, Suite 1C
Las Cruces, New Mexico 88011
Re:Virgin Galactic Holdings, Inc
Registration Statement on Form S-3
Filed May 28, 2021
File No. 333-256607
Dear Ms. Kley:
            We have limited our review of your registration statement to those issues we have
addressed in our 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
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.

 FirstName LastNameMichelle  Kley
 Comapany NameVirgin Galactic Holdings, Inc
 June 16, 2021 Page 2
 FirstName LastName
Michelle  Kley
Virgin Galactic Holdings, Inc
June 16, 2021
Page 2
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Irene Barberena-Meissner at (202) 551-6548 or Kevin Dougherty at (202)
551-3271 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Drew Capurro, Esq.

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August 4, 2020

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-6010

Attention: Kevin Dougherty

Re: Virgin Galactic Holdings, Inc.

Registration Statement on Form S-1

Filed on August 3, 2020

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned, for itself and the several underwriters, hereby join in the request of Virgin Galactic Holdings, Inc. that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective as of 5:00 p.m. Eastern Time on August 5, 2020, or as soon as practicable thereafter. Pursuant to Rule 460 of the General Rules and Regulations under the Act, the undersigned advise that as of the date hereof, approximately 2,000 copies of the Preliminary Prospectus dated August 3, 2020 are expected to be distributed to prospective underwriters and dealers, institutional investors, retail investors and others.

The undersigned advise that they have complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

* * *

[Signature Page Follows]

Very truly yours,

CREDIT SUISSE SECURITIES (USA) LLC

By:

  /s/ Jesse Chasse

 Name: Jesse Chasse

 Title:   Director

MORGAN STANLEY & CO. LLC

By:

 /s/ Phillip Ingle

 Name: Phillip Ingle

 Title:   Managing Director

[Signature Page to Acceleration Request Letter]

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Virgin Galactic Holdings, Inc.

166 North Roadrunner Parkway, Suite 1C

Las Cruces, New Mexico 88011

August 4, 2020

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-6010

Attention:  Kevin Dougherty

 Re: Virgin Galactic Holdings, Inc.

  Registration Statement on Form S-1

  Filed on August 3, 2020

Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-1 filed on August 3, 2020 (the “Registration Statement”) of Virgin Galactic Holdings, Inc. (the “Company”).  We respectfully request that the Registration Statement become effective as of 5:00 p.m. Eastern Time on August 5, 2020, or as soon as practicable thereafter.  Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Drew Capurro at (714) 755-8008 or, in his absence, Benjamin Sosin at (714) 755-2267.

Thank you for your assistance in this matter.

Very truly yours,

VIRGIN GALACTIC HOLDINGS, INC.

By: /s/ Michelle Kley

 Michelle Kley

 Executive Vice President,

 General Counsel and Secretary

cc: Michael Colglazier, Virgin Galactic Holdings, Inc.

 Jonathan Campagna, Virgin Galactic Holdings, Inc.

 Drew Capurro, Latham & Watkins LLP

 Benjamin D. Sosin, Latham & Watkins LLP

 Gregg Noel, Skadden, Arps, Slate, Meagher & Flom LLP

United States securities and exchange commission logo
July 22, 2020
Jon Campagna
Chief Financial Officer
Virgin Galactic Holdings, Inc
166 North Roadrunner Parkway, Suite 1C
Las Cruces, New Mexico 88011
Re:Virgin Galactic Holdings, Inc.
Draft Registration Statement on Form S-1
Submitted July 20, 2020
CIK No. 0001706946
Dear Mr. Campagna:
            This is to advise you that we do not intend to review your registration statement.
            We request that you publicly file your registration statement no later than 48 hours prior
to the requested effective date and time. Please refer to Rules 460 and 461 regarding requests for
acceleration. 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 Kevin Dougherty at (202) 551-3271 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Drew Capurro

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Virgin Galactic Holdings, Inc.

166 North Roadrunner Parkway, Suite 1C

Las Cruces, New Mexico 88011

May 11, 2020

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Attention: Karina Dorin

Re: Virgin Galactic Holdings, Inc.

Registration Statement on Form S-1, as amended

File No. 333-237961

Dear Ms. Dorin:

Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, the undersigned, Virgin Galactic Holdings, Inc., a Delaware corporation, hereby requests acceleration of the effective date of the Registration Statement referred to above, as amended to date, so that it may become effective at 4:00 PM Eastern Daylight Time on May 13, 2020, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Drew Capurro at (714) 755-8008.

Thank you for your assistance in this matter.

Very truly yours,

VIRGIN GALACTIC HOLDINGS, INC.

a Delaware corporation

By: /s/ Michelle Kley

 Michelle Kley

 Executive Vice President,

 General Counsel and Secretary

cc: Drew Capurro, Latham & Watkins LLP

United States securities and exchange commission logo
May 8, 2020
George Whitesides
Chief Executive Officer
Virgin Galactic Holdings, Inc.
166 North Roadrunner Parkway, Suite 1C
Las Cruces, New Mexico 88011
Re:Virgin Galactic Holdings, Inc.
Registration Statement on Form S-1
Filed May 1, 2020
File No. 333-237961
Dear Mr. Whitesides:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 Karina Dorin, Staff Attorney, at (202) 551-3763 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Drew Capurro

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 SOCIAL CAPITAL HEDOSOPHIA HOLDINGS CORP.

120 Hawthorne Avenue

 Palo Alto,
California 94301

 October 8, 2019

VIA EDGAR

 Irene Barberena-Meissner

Office of Transportation and Leisure

 Division of Corporation
Finance

 U.S. Securities and Exchange Commission

 100 F
Street, NE

 Washington, D.C. 20549

RE:
 Social Capital Hedosophia Holdings Corp. (the “Company”)

Registration Statement on Form S-4

File No. 333-233098

Dear Ms. Barberena-Meissner:

 Pursuant to
Rule 461(a) under the Securities Act of 1933, as amended, the Company hereby respectfully requests that the effective date of the Company’s Registration Statement on Form S-4 (File No. 333-233098) be accelerated by the Securities and Exchange Commission to 4:30 p.m. Washington D.C. time on October 9, 2019 or as soon as practicable thereafter.

 We request that we be notified of such effectiveness by a telephone call to Howard Ellin of
Skadden, Arps, Slate, Meagher & Flom LLP at (212) 735-2438 and that such effectiveness also be confirmed in writing.

Very truly yours,

Social Capital Hedosophia Holdings Corp.

By:

/s/ Chamath Palihapitiya

Name: Chamath Palihapitiya

Title: Chief Executive Officer

cc:
 James Cahillane

Virgin Group

cc:
 Christopher M. Barlow

Skadden, Arps, Slate, Meagher & Flom LLP

cc:
 Shayne Kennedy and Justin G. Hamill

Latham & Watkins LLP

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 DIRECT DIAL

(212) 735-2438

DIRECT FAX

 (917) 777-2438

 EMAIL
ADDRESS

 Howard.ellin@SKADDEN.COM

 SKADDEN, ARPS, SLATE, MEAGHER & FLOM
LLP

 4 TIMES SQUARE

NEW YORK 10036-6522

 TEL: (212)
735-3000

 FAX: (212) 735-2000

www.skadden.com

September 25, 2019

 FIRM/AFFILIATE

OFFICES

—————-

BOSTON

 CHICAGO

HOUSTON

 NEW YORK

PALO ALTO

 WASHINGTON, D.C.

WILMINGTON

—————-

BEIJING

 BRUSSELS

FRANKFURT

 HONG KONG

LONDON

 MOSCOW

MUNICH

 PARIS

SÃO PAULO

 SEOUL

SHANGHAI

 SINGAPORE

SYDNEY

 TOKYO

TORONTO

 VIA EDGAR

 Irene
Barberena-Meissner

 Office of Transportation and Leisure

Division of Corporation Finance

 U.S. Securities and Exchange
Commission

 100 F Street, NE

 Washington, D.C. 20549

RE:
 Social Capital Hedosophia Holdings Corp.

 Registration Statement on Form S-4

 Filed September 12, 2019

 File No. 333-233098

Dear Ms. Barberena-Meissner:

 On behalf of
Social Capital Hedosophia Holdings Corp. (the “Company,” “we” or “our”), we have filed today Amendment No. 2 to the above Registration Statement on
Form S-4 (the “Amended Registration Statement”) in response to the comments of the staff (“Staff”) of the Division of Corporation Finance of the U.S. Securities and
Exchange Commission received by letter dated September 23, 2019, concerning the above Registration Statement on Form S-4 filed on September 12, 2019.

The changes reflected in the Amended Registration Statement include those made in response to the Staff’s comment as well as other
updates. For the convenience of the Staff, we also have sent to you paper copies of this letter and copies of the Amended Registration Statement marked to show changes from the Registration Statement. All references in this letter to page numbers
and captions correspond to the page numbers and captions in the Amended Registration Statement.

 U.S. Securities and Exchange Commission

September 25, 2019

  Page
 2

 Projected Financial Information, page 128

1.
 We note your response to our prior comment 5. As SCH management based its valuation of the
VG Companies on an analysis of the aggregate potential cash flows to be generated by the “Virgin Galactic” business, as projected by VG management, please revise to disclose these cash flow projections.

The Company respectfully acknowledges the Staff’s comment and advises the Staff that the term “aggregate potential cash flows,”
as referenced in the disclosure and as it relates to SCH management’s evaluation of the VG Companies, was used to refer to SCH management’s comparison of projected EBITDA to projected capital expenditures, each as provided by VG
Management and as disclosed on page 129 of the Amended Registration Statement. Other than this metric, there were no other material projections of cash flow used in evaluating the VG Companies. In response to the Staff’s comment, the
Company has revised its disclosure on pages 114 and 115.

 *    *    *

 Please contact me at (212) 735-2438 should you require further
information.

 Very truly yours,

/s/ Howard Ellin

Howard Ellin

cc:
 Chamath Palihapitiya

 Social Capital Hedosophia Holdings Corp.

cc:
 James Cahillane

 Virgin Group

cc:
 Christopher M. Barlow

 Skadden, Arps, Slate, Meagher & Flom LLP

cc:
 Shayne Kennedy and Justin G. Hamill

 Latham & Watkins LLP

September 23, 2019
Chamath Palihapitiya
Chief Executive Officer
Social Capital Hedosophia Holdings Corp.
120 Hawthorne Avenue
Palo Alto, CA 94301
Re:Social Capital Hedosophia Holdings Corp.
Registration Statement on Form S-4
Filed September 12, 2019
File No. 333-233098
Dear Mr. Palihapitiya:
            We have reviewed your amended registration statement and 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our September 3, 2019 letter.
Registration Statement on Form S-4
Projected Financial Information, page 128
1.We note your response to our prior comment 5.  As SCH management based its valuation
of the VG Companies on an analysis of the aggregate potential cash flows to be generated
by the “Virgin Galactic” business, as projected by VG management, please revise to
disclose these cash flow projections.
             You may contact Theresa Brilliant, Staff Accountant, at 202-551-3307 or Andrew Mew,
Senior Assistant Chief Accountant, at 202-551-3377 if you have questions regarding comments
on the financial statements and related matters.  Please contact Irene Barberena-Meissner, Staff
Attorney, at 202-551-6548 or Kevin Dougherty, Staff Attorney, at 202-551-3271 with any other
questions.

 FirstName LastNameChamath Palihapitiya
 Comapany NameSocial Capital Hedosophia Holdings Corp.
 September 23, 2019 Page 2
 FirstName LastName
Chamath Palihapitiya
Social Capital Hedosophia Holdings Corp.
September 23, 2019
Page 2
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure
cc:       Howard Ellin

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 DIRECT DIAL

(212) 735-2438

DIRECT FAX

 (917) 777-2438

 EMAIL
ADDRESS

 Howard.ellin@SKADDEN.COM

 SKADDEN, ARPS, SLATE, MEAGHER & FLOM
LLP

 4 TIMES SQUARE

NEW YORK 10036-6522

 TEL: (212)
735-3000

 FAX: (212) 735-2000

www.skadden.com

September 12, 2019

 FIRM/AFFILIATE

OFFICES

—————-

BOSTON

 CHICAGO

HOUSTON

 NEW YORK

PALO ALTO

 WASHINGTON, D.C.

WILMINGTON

—————-

BEIJING

 BRUSSELS

FRANKFURT

 HONG KONG

LONDON

 MOSCOW

MUNICH

 PARIS

SÃO PAULO

 SEOUL

SHANGHAI

 SINGAPORE

SYDNEY

 TOKYO

TORONTO

 VIA EDGAR

 Irene
Barberena-Meissner

 Office of Transportation and Leisure

Division of Corporation Finance

 U.S. Securities and Exchange
Commission

 100 F Street, NE

 Washington, D.C. 20549

RE:
 Social Capital Hedosophia Holdings Corp.

 Registration Statement on Form S-4

 Filed August 7, 2019

 File No. 333-233098

Dear Ms. Barberena-Meissner:

 On behalf of
Social Capital Hedosophia Holdings Corp. (the “Company,” “we” or “our”), we have filed today Amendment No. 1 to the above Registration Statement on Form
S-4 (the “Amended Registration Statement”) in response to the comments of the staff (“Staff”) of the Division of Corporation Finance of the U.S. Securities and Exchange
Commission received by letter dated September 3, 2019, concerning the above Registration Statement on Form S-4 filed on August 7, 2019.

The changes reflected in the Amended Registration Statement include those made in response to the Staff’s comment as well as other
updates. For the convenience of the Staff, we also have sent to you paper copies of this letter and copies of the Amended Registration Statement marked to show changes from the Registration Statement. All references in this letter to page numbers
and captions correspond to the page numbers and captions in the Amended Registration Statement.

 U.S. Securities and Exchange Commission

September 12, 2019

  Page
 2

 Prospectus Summary, page 1

1.
 Please revise to provide the dates of the U.S. Chamber of Commerce article you cite here and the Credit
Suisse Research Institute report you cite on page 201.

 In response to the Staff’s comment, the Company has
revised its disclosure on pages 1, 10, 124, 199, 201 and 203.

2.
 Please disclose your expected timeline of achieving and the substance of your remaining verification and
validation steps that must be completed before the FAA will clear you to include customers on your spaceflights.

In response to the Staff’s comment, the Company has revised its disclosure on pages 2, 3, 46, 200 and 217.

Risk Factors

 Risks Related to VGH,
Inc.’s Business

 Due to the inherent risks associated with commercial spaceflight..., page 37

3.
 Please disclose your conclusions about and steps you have taken to address the causes of the
October 31, 2014 in-flight incident.

 In response to the
Staff’s comment, the Company has revised its disclosure on page 39.

 Risks Related to the Consummation of the Domestication

The provisions of the proposed certificate of incorporation requiring exclusive forum in the Court of Chancery of the State of Delaware..., page 71

4.
 You disclose here and elsewhere that your certificate of incorporation includes a forum selection
provision identifying the Court of Chancery of the State of Delaware as the exclusive forum for certain litigation, including any “derivative action,” but that, notwithstanding this provision, your proposed certificate of incorporation
will provide that the exclusive forum provision will not apply to suits brought to enforce a duty or liability created by the Securities Act or the Exchange Act or any other claim for which the federal courts have exclusive jurisdiction. However,
your form of Certificate of Incorporation included as Annex F does not include this limitation. If this provision does not apply to actions arising under the Securities Act or Exchange Act, please ensure that the exclusive forum provision in your
Certificate of Incorporation states this clearly.

 In response to the Staff’s comment, the Company has
revised its disclosure on pages 73, 149, 150 and 267, as well as page F-5 of Annex F.

 U.S. Securities and Exchange Commission

September 12, 2019

  Page
 3

 Background to the Business Combination, page 111

5.
 We note your disclosure that the initial non-binding letter SCH
sent to Virgin management on January 24, 2019 included an initial enterprise value for the Virgin Galactic business operated by the VG Companies and the Virgin Orbit business of $1.5 billion on a
pre-transaction, debt-free, cash-free basis. After the Virgin Orbit business was excluded, on March 2, 2019, you further disclose that SCH sent to Virgin management the first version of a new non-binding letter of intent, and that this $850 million (with no earn-out opportunity) and a secondary repurchase of up to $150 million valuation fell within the
lower range of valuations that SCH management had considered for the VG Companies alone. Please revise to provide additional details regarding how SCH determined the valuation of the Virgin businesses initially and then the range of valuations for
the VG Companies alone.

 In response to the Staff’s comment, the Company has revised its disclosure on pages
114 and 115.

 Projected Financial Information, page 128

6.
 We note your disclosure regarding the financial projections provided by management of the VG Companies to
SCH. Please disclose, and quantify as appropriate, the material assumptions underlying these projections. For example, we note that the projected financial summary on slide 61 from the investor presentation filed on an Exhibit 99.2 to a Form 8-K, Rule 425 filing, filed on July 9, 2019 includes assumptions as to the numbers of vehicles, total flights and total number of passengers, among other assumptions disclosed that appear to underlie the
revenue projections.

 In response to the Staff’s comment, the Company has revised its disclosure on page
130.

 U.S. Federal Income Tax Considerations, page 163

7.
 You disclose that you intend the domestication will qualify as a “reorganization” within the
meaning of Section 368(a)(1)(F) of the Code. As such, a tax opinion appears required. If you elect to use a short-form opinion, please note that the opinion and the related tax disclosure in the prospectus both must state clearly that the
disclosure in the tax consequences section of the prospectus is the opinion of counsel and that disclosure must clearly identify and articulate the opinion being rendered. Please refer to Section III of Staff Legal Bulletin 19 (Oct. 14, 2011).

 In response to the Staff’s comment, the Company has revised its disclosure on page 166. The tax opinion
will be filed in a subsequent amendment to the Registration Statement.

 U.S. Securities and Exchange Commission

September 12, 2019

  Page
 4

 Unaudited Pro Forma Condensed Combined Financial Information, page 173

8.
 Please tell us your consideration of reflecting the new trademark license agreement granting the rights
to use certain VIRGIN marks in the pro forma financial statements pursuant to Item 11-02 of Regulation S-X.

In response to the Staff’s comment, the Company has revised its disclosure on pages 176, 179, 180 and 183.

Information About SCH

 Directors and
Executive Officers, page 188

9.
 A number of the biographical sketches of your officers and directors are unclear with regard to the most
recent five years of business experience, including positions held during that time. In particular, please revise the sketches for Messrs. Williams and Bain to eliminate any gaps or ambiguities regarding their experience during the most recent five
years. Please also disclose any other directorships held by them in another public company during that timeframe. In this regard, we note that Mr. Palihapitiya appears to serve as a director of Slack Technologies Inc. See Item 401(e) of
Regulation S-K.

 The Company has revised the disclosure as suggested.
Please see pages 190, 191 and 192.

 Facilities, page 216

10.
 Please file copies of the lease agreements for your facilities at the Mojave Air and Space Port in
Mojave, California or explain why they are not required to be filed. Refer to Item 601(b)(10) of Regulation S-K.

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised the exhibit index to include the
VG Companies’ leases at the Mojave Air and Space Port that are material to the VG Companies and has filed such leases with the Amended Registration Statement.

 U.S. Securities and Exchange Commission

September 12, 2019

  Page
 5

 The VG Companies Management’s Discussion and Analysis of Financial Condition and Results of
Operations

 Funding Requirements, page 227

11.
 We note that the VG Companies have two additional SpaceShipTwo vehicles under construction to expand the
fleet to a total of five SpaceShipTwo by the end of 2023, in addition to expenditures related to the anticipated launch in 2020. Please provide an estimate of the amount of capital necessary to accomplish these goals as well as the timing of such
costs. See Item 303(a)(2) of Regulation S-K.

 The Company respectfully
acknowledges the Staff’s comment. In response, the Company supplementally advises the Staff that, consistent with the disclosure on page 230 of the Amended Registration Statement, it currently believes that following the consummation of the
Business Combination, the Primary Purchase, if any, and the Reinvestment, if any, VGH, Inc. will have sufficient cash and cash equivalents to fund its operating expenses and capital expenditures (including those related the commercial launch of its
human space flight program) for at least the next 24 months. Furthermore, the Company has revised the disclosure to identify the anticipated remaining direct costs for completing the two spaceships currently under construction and to note that the
costs for construction of additional spaceships are expected to decrease as the Company continues to scale its operations.

 Executive Compensation

 Executive Compensation Arrangements, page 242

12.
 Please file copies of your employment agreements with George T. Whitesides, Michael Moses, and Enrico
Palermo as exhibits. Refer to Item 601(b)(10)(iii)(A) of Regulation S-K.

The Company respectfully acknowledges the Staff’s comment and advises the Staff that it has revised the exhibit index to include the form
of employment agreements with Messrs. Whitesides, Moses and Palermo and the Company undertakes to file such agreements with a subsequent amendment to the Registration Statement.

Virgin Galactic Business Financial Statements

Basis of Presentation, page F-31

13.
 We note that the carve-out historical combined financial
statements of the Virgin Galactic Business do not reflect any attribution of debt or allocation of interest expense. Please tell us your consideration of attributing debt or allocating interest expense to the
carve-out financial statements and the basis for your conclusion of your current treatment.

The Company acknowledges the Staff’s comment and respectfully advises the Staff that when determining the appropriate basis of
presentation of the carve-out financial statements, the Company considered the guidance in both SAB Topic 1.B.1 and SAB Topic 5.T, among other guidance, which provides that the historical financial statements
should reflect all legal obligations and costs of doing business, including obligations and expenses incurred by the Parent Company on behalf of or for the benefit of the Virgin Galactic Business.

The Company advises the Staff that the Virgin Galactic Business does not have any legal obligation, including any joint or several obligations,
associated with the Parent Company’s debt. Furthermore, the Virgin Galactic Business will not assume nor will the Parent Company transfer any portion of the Parent Company’s debt to the Virgin Galactic

 U.S. Securities and Exchange Commission

September 12, 2019

  Page
 6

Business. Historically, there were no interest charges incurred, imputed, or allocated to the Virgin Galactic Business from the Parent Company. Accordingly, debt has not been attributed and
interest expense has not been allocated to the Virgin Galactic Business in the carve-out financial statements.

The Company believes it has provided sufficient and meaningful disclosure for its basis of presentation in Note 1 of the combined financial
statements of the Virgin Galactic Business related to cash transfers to and from the Parent Company and its net parent investment balance.

 Customer
Deposits, page F-31

14.
 Please provide an accounting policy for your treatment of customer deposits, including the circumstances
in which the deposits become nonrefundable.

 In response to the Staff’s comment, the Company has revised its
disclosure on page F-41.

 *     *     *

 U.S. Securities and Exchange Commission

September 12, 2019

  Page
 7

 Please contact me at (212) 735-2438 should you require further
information.

 Very truly yours,

/s/ Howard Ellin

Howard Ellin

cc:
 Chamath Palihapitiya

Social Capital Hedosophia Holdings Corp.

cc:
 James Cahillane

Virgin Group

cc:
 Christopher M. Barlow

Skadden, Arps, Slate, Meagher & Flom LLP

cc:
 Shayne Kennedy and Justin G. Hamill

Latham & Watkins LLP

September 3, 2019
Chamath Palihapitiya
Chief Executive Officer
Social Capital Hedosophia Holdings Corp.
120 Hawthorne Avenue
Palo Alto, CA 94301
Re:Social Capital Hedosophia Holdings Corp.
Registration Statement on Form S-4
Filed August 7, 2019
File No. 333-233098
Dear Mr. Palihapitiya:
            We have reviewed your registration statement and 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-4 filed August 7, 2019
Prospectus Summary, page 1
1.Please revise to provide the dates of the U.S. Chamber of Commerce article you cite here
and the Credit Suisse Research Institute report you cite on page 201.
2.Please disclose your expected timeline of achieving and the substance of  your remaining
verification and validation steps that must be completed before the FAA will clear you to
include customers on your spaceflights.

 FirstName LastNameChamath Palihapitiya
 Comapany NameSocial Capital Hedosophia Holdings Corp.
 September 3, 2019 Page 2
 FirstName LastNameChamath Palihapitiya
Social Capital Hedosophia Holdings Corp.
September 3, 2019
Page 2
Risk Factors
Risks Related to VGH, Inc.'s Business
Due to the inherent risks associated with commercial spaceflight..., page 37
3.Please disclose your conclusions about and steps you have taken to address the causes of
the October 31, 2014 in-flight incident.
Risks Related to the Consummation of the Domestication
The provisions of the proposed certificate of incorporation requiring exclusive forum in the
Court of Chancery of the State of Delaware..., page 71
4.You disclose here and elsewhere that your certificate of incorporation includes a forum
selection provision identifying the Court of Chancery of the State of Delaware as the
exclusive forum for certain litigation, including any “derivative action,” but that,
notwithstanding this provision, your proposed certificate of incorporation will provide that
the exclusive forum provision will not apply to suits brought to enforce a duty or liability
created by the Securities Act or the Exchange Act or any other claim for which the federal
courts have exclusive jurisdiction.  However, your form of Certificate of Incorporation
included as Annex F does not include this limitation.  If this provision does not apply to
actions arising under the Securities Act or Exchange Act, please ensure that the exclusive
forum provision in your Certificate of Incorporation states this clearly.
Background to the Business Combination, page 111
5.We note your disclosure that the initial non-binding letter SCH sent to Virgin management
on January 24, 2019 included an initial enterprise value for the Virgin Galactic business
operated by the VG Companies and the Virgin Orbit business of $1.5 billion on a pre-
transaction, debt-free, cash-free basis.  After the Virgin Orbit business was excluded, on
March 2, 2019, you further disclose that SCH sent to Virgin management the first version
of a new non-binding letter of intent, and that this $850 million (with no earn-out
opportunity) and a secondary repurchase of up to $150 million valuation fell within the
lower range of valuations that SCH management had considered for the VG Companies
alone. Please revise to provide additional details regarding how SCH determined the
valuation of the Virgin businesses initially and then the range of valuations for the VG
Companies alone.
Projected Financial Information, page 128
6.We note your disclosure regarding the financial projections provided by management of
the VG Companies to SCH.  Please disclose, and quantify as appropriate, the material
assumptions underlying these projections.  For example, we note that the projected
financial summary on slide 61 from the investor presentation filed on an Exhibit 99.2 to a
Form 8-K, Rule 425 filing, filed on July 9, 2019 includes assumptions as to the numbers
of vehicles, total flights and total number of passengers, among other assumptions

 FirstName LastNameChamath Palihapitiya
 Comapany NameSocial Capital Hedosophia Holdings Corp.
 September 3, 2019 Page 3
 FirstName LastNameChamath Palihapitiya
Social Capital Hedosophia Holdings Corp.
September 3, 2019
Page 3
disclosed that appear to underlie the revenue projections.
U.S. Federal Income Tax Considerations, page 163
7.You disclose that you intend the domestication will qualify as a “reorganization” within
the meaning of Section 368(a)(1)(F) of the Code.  As such, a tax opinion appears
required.  If you elect to use a short-form opinion, please note that the opinion and the
related tax disclosure in the prospectus both must state clearly that the disclosure in the tax
consequences section of the prospectus is the opinion of counsel and that disclosure must
clearly identify and articulate the opinion being rendered.  Please refer to Section III of
Staff Legal Bulletin 19 (Oct. 14, 2011).
Unaudited Pro Forma Condensed Combined Financial Information, page 173
8.Please tell us your consideration of reflecting the new trademark license agreement
granting the rights to use certain VIRGIN marks in the pro forma financial statements
pursuant to Item 11-02 of Regulation S-X.
Information About SCH
Directors and Executive Officers, page 188
9.A number of the biographical sketches of your officers and directors are unclear with
regard to the most recent five years of business experience, including positions held
during that time.  In particular, please revise the sketches for Messrs. Williamsand Bain to
eliminate any gaps or ambiguities regarding their experience during the most recent five
years.  Please also disclose any other directorships held by them in another public
company during that timeframe.  In this regard, we note that Mr. Palihapitiya appears
serve as a director of Slack Technologies Inc.  See Item 401(e) of Regulation S-K.
Facilities, page 216
10.Please file copies of the lease agreements for your facilities at the Mojave Air and Space
Port in Mojave, California or explain why they are not required to be filed. Refer to Item
601(b)(10) of Regulation S-K.
The VG Companies Management's Discussion and Analysis of Financial Condition and Results
of Operations
Funding Requirements, page 227
11.We note that the VG Companies have two additional SpaceShipTwo vehicles under
construction to expand the fleet to a total of five SpaceShipTwo by the end of 2023, in
addition to expenditures related to the anticipated launch in 2020.  Please provide an
estimate of the amount of capital necessary to accomplish these goals as well as the timing
of such costs.  See Item 303(a)(2) of Regulation S-K.

 FirstName LastNameChamath Palihapitiya
 Comapany NameSocial Capital Hedosophia Holdings Corp.
 September 3, 2019 Page 4
 FirstName LastName
Chamath Palihapitiya
Social Capital Hedosophia Holdings Corp.
September 3, 2019
Page 4
Executive Compensation
Executive Compensation Arrangements, page 242
12.Please file copies of your employment agreements with George T. Whitesides, Michael
Moses, and Enrico Palermo as exhibits.  Refer to Item 601(b)(10)(iii)(A) of Regulation S-
K.
Virgin Galactic Business Financial Statements
Basis of Presentation, page F-31
13.We note that the carve-out historical combined financial statements of the Virgin Galactic
Business do not reflect any attribution of debt or allocation of interest expense.  Please tell
us your consideration of attributing debt or allocating interest expense to the carve-out
financial statements and the basis for your conclusion of your current treatment.
Customer Deposits, page F-31
14.Please provide an accounting policy for your treatment of customer deposits, including the
circumstances in which the deposits become nonrefundable.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            You may contact Theresa Brillant, Staff Accountant, at 202-551-3307, or Andrew Mew,
Senor Assistant Chief Accountant, at 202-551-3377 if you have questions regarding comments
on the financial statements and related matters.  Please contact Irene Barberena-Meissner, Staff
Attorney, at 202-551-6548 or Kevin Dougherty, Staff Attorney, at 202-551-3271 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure
cc:       Howard Ellin

CORRESP
1
filename1.htm

SOCIAL CAPITAL HEDOSOPHIA HOLDINGS CORP.

120 Hawthorne Avenue

Palo Alto, California 94301

September 11, 2017

VIA EMAIL & EDGAR

Ms. Erin E. Martin

Special Counsel

Office of Financial Services

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

 Re: Social Capital Hedosophia Holdings Corp. (the “Company”)

Registration Statement on Form S-1 (Registration
No. 333-220130)

Dear Ms. Martin:

Pursuant to Rule 461(a) under the Securities
Act of 1933, as amended, we respectfully request that the effective date of the Company’s Registration Statement on Form
S-1 (File No. 333-220130) be accelerated by the Securities and Exchange Commission to 4:00 p.m. Washington D.C. time on September
13, 2017 or as soon as practicable thereafter.

We request that we be notified of such effectiveness
by a telephone call to Jonathan Ko of Skadden, Arps, Slate, Meagher & Flom LLP at (213) 687-5527 and that such effectiveness
also be confirmed in writing.

    Very truly yours,

    Social Capital Hedosophia Holdings Corp.

    By:
    /s/ Chamath Palihapitiya

    Name:
    Chamath Palihapitiya

    Title:
    Chief Executive Officer

 cc: Skadden, Arps, Slate, Meagher & Flom LLP

Jonathan Ko

 cc: Shearman & Sterling LLP

Harald Halbhuber, Esq. and Ilir Mujalovic,
Esq.

CORRESP
1
filename1.htm

September 11, 2017

VIA EDGAR

Erin E. Martin

Special Counsel

Office of Financial Services

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

 Attn: Ms. Erin Martin

Special Counsel

Office of Financial Services

 Re: Social Capital Hedosophia Holdings Corp.

Registration Statement on Form S-1

Filed September 6, 2017, as amended

File No. 333-220130

Dear Ms. Martin:

Pursuant to Rule 461 of the General Rules and Regulations under
the Securities Act of 1933, as amended (the “Act”), the undersigned hereby joins in the request of Social Capital Hedosophia
Holdings Corp. that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become
effective at 4:00 p.m. Washington D.C. time on September 13, 2017, or as soon thereafter as practicable.

Pursuant to Rule 460 of the General Rules and Regulations under
the Act, the undersigned advises that as of the date hereof, 177 copies of the Preliminary Prospectus dated September 6, 2017 have
been distributed to prospective underwriters and dealers, institutional investors, retail investors and others.

The undersigned advises that it has complied and will continue
to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[signature page follows]

    Very truly yours,

    CREDIT SUISSE SECURITIES (USA) LLC

    CREDIT SUISSE SECURITIES (USA) LLC

    By:
    /s/ Christopher Eby

    Name: Christopher Eby

    Title: Director

CORRESP
1
filename1.htm

    Skadden,
    Arps, Slate, Meagher & Flom llp

    300
        South Grand Avenue

        Los
        Angeles, California 90071-3144

    FIRM/AFFILIATE
                                         OFFICES

        -----------

        BOSTON

        CHICAGO

        HOUSTON

        NEW
        YORK

        PALO
        ALTO

        WASHINGTON,
        D.C.

        WILMINGTON

        -----------

        BEIJING

        BRUSSELS

        FRANKFURT

        HONG
        KONG

        LONDON

        MOSCOW

        MUNICH

        PARIS

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        PAULO

        SEOUL

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        SINGAPORE

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    ________

                           DIRECT
                           DIAL

        (213)
        687-5527

        DIRECT
        FAX

        (213)
        621-5527

        EMAIL
        ADDRESS

        JONATHAN.KO@SKADDEN.COM

        TEL:
        (213) 687-5000

        FAX:
        (213) 687-5600

        www.skadden.com

September
6, 2017

    VIA
        EDGAR

        Erin
        E. Martin

        Special Counsel

        Office of Financial Services

        Division of Corporation Finance

        U.S. Securities and Exchange Commission

        100 F Street, NE

        Washington, D.C. 20549

    RE:
    Social Capital Hedosophia Holdings Corp.

    Registration Statement on Form S-1

    Filed September 6, 2017

    File No. 333-220130

Dear Ms. Martin:

On behalf of Social Capital Hedosophia
Holdings Corp. (the “Company”), in connection with the proposed initial public offering of the
Company’s securities, the Company has filed today Amendment Number 2  to its Registration Statement on Form S-1 (the
“Amended Registration Statement”). The changes reflected in the Amended Registration Statement include
those made to add an additional director as well as other updates.

For the convenience of the Staff, we also
have sent to you paper copies of this letter and copies of the Amended Registration Statement marked to show changes from Amendment
Number 1 to the Company’s Registration Statement filed on September 1, 2017.

U.S. Securities and Exchange Commission

September 6, 2017

Page 2

Please contact me at (213) 687-5527 should you
require further information.

Very truly yours,

/s/ Jonathan Ko

Jonathan Ko

    cc:
    Social Capital Hedosophia Holdings Corp.

    Chamath Palihapitiya

    cc:
    Shearman & Sterling LLP

    Harald Halbhuber, Esq. and Ilir Mujalovic, Esq.

CORRESP
1
filename1.htm

Skadden,
Arps, Slate, Meagher & Flom llp

300
South Grand Avenue

Los
Angeles, California 90071-3144

                                DIRECT
                           DIAL

(213) 687-5527

       DIRECT FAX

(213) 621-5527

       EMAIL ADDRESS

JONATHAN.KO@SKADDEN.COM

    ________

TEL:
(213) 687-5000

FAX:
(213) 687-5600

www.skadden.com

September 1, 2017

    FIRM/AFFILIATE
                           OFFICES

-----------

BOSTON

CHICAGO

HOUSTON

NEW YORK

PALO ALTO

WASHINGTON,
D.C.

WILMINGTON

-----------

BEIJING

BRUSSELS

FRANKFURT

HONG KONG

LONDON

MOSCOW

MUNICH

PARIS

SÃO
PAULO

SEOUL

SHANGHAI

SINGAPORE

SYDNEY

TOKYO

TORONTO

VIA EDGAR

Erin E. Martin

Special Counsel

Office of Financial Services

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

 RE: Social Capital Hedosophia Holdings Corp.

Registration Statement on Form
S-1

Filed September 1, 2017

File No. 333-220130

Dear Ms. Martin:

On behalf of Social Capital Hedosophia Holdings
Corp. (the “Company”), in connection with the proposed initial public offering of the Company’s securities,
the Company has filed today an amendment to its Registration Statement on Form S-1 (the “Amended Registration Statement”).
The changes reflected in the Amended Registration Statement include those made to update the date of the Company’s audited
balance sheet to June 30, 2017 and the filing of certain exhibits as well as other updates.

For the convenience of the Staff, we also
have sent to you paper copies of this letter and copies of the Amended Registration Statement marked to show changes from the Company’s
Registration Statement filed on August 23, 2017.

U.S. Securities and Exchange Commission

September 1, 2017

Page 2

Please contact me at (213) 687-5527 should you
require further information.

    Very truly yours,

    /s/ Jonathan Ko

    Jonathan Ko

 cc: Social Capital Hedosophia Holdings Corp.

Chamath Palihapitiya

 cc: Shearman & Sterling LLP

Harald Halbhuber, Esq. and Ilir
Mujalovic, Esq.

CORRESP
1
filename1.htm

Skadden,
Arps, Slate, Meagher & Flom llp

                                                            DIRECT
DIAL

(213) 687-5527

DIRECT FAX

(213) 621-5527

EMAIL ADDRESS

JONATHAN.KO@SKADDEN.COM

    300 South Grand Avenue
Los
Angeles, California 90071-3144

________

TEL: (213) 687-5000

FAX: (213) 687-5600

www.skadden.com

August 23, 2017

    FIRM/AFFILIATE

                           OFFICES

        -----------

        BOSTON

        CHICAGO

        HOUSTON

        NEW YORK

        PALO ALTO

        WASHINGTON, D.C.

        WILMINGTON

        -----------

        BEIJING

        BRUSSELS

        FRANKFURT

        HONG KONG

        LONDON

        MOSCOW

        MUNICH

        PARIS

        SÃO PAULO

        SEOUL

        SHANGHAI

        SINGAPORE

        SYDNEY

        TOKYO

        TORONTO

VIA EDGAR

Erin E. Martin

Special Counsel

Office of Financial Services

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

RE:  Social Capital Hedosophia Holdings Corp.

                                                                                Registration
                                         Statement on Form S-1

                                                                                Filed August 23, 2017

                                                                                CIK
                                         No. 0001706946

Dear Ms. Martin:

On behalf of Social Capital Hedosophia
Holdings Corp. (the “Company,” “we,” or “our”), in connection with the
proposed initial public offering of the Company’s securities, we have filed today the Company’s Registration Statement
on Form S-1 (the “Registration Statement”). The changes reflected in the Registration Statement include those
made to reflect the public filing, an increase in the offering size and the filing of certain exhibits as well as other updates.

We advise the staff (“Staff”)
of the Division of Corporation Finance of the U.S. Securities and Exchange Commission that we are providing to the Staff on a supplemental
basis copies of the written communications, as defined in Rule 405 under the Securities Act of 1933, as amended (the “Securities
Act”), that were used in meetings with potential investors in reliance on Section 5(d) of the Securities Act. Pursuant to
Rule 418 under the Securities Act, such copies shall not be deemed to be filed with, or a part of or included in, the Registration
Statement. Additionally, pursuant to Rule 418(b) under the Securities Act, we request that the Staff return or destroy copies of
such materials to us. We confirm that no copies of such written communications were retained by potential investors. Other than
these materials, we have not presented any written communications to potential investors in reliance on Section 5(d) of the Securities
Act, and we have not authorized anyone to do so on our behalf.

*   *   *

U.S. Securities and Exchange Commission

August 23, 2017

Page 2

Please contact me at (213) 687-5527 should you
require further information.

Very truly yours,

/s/ Jonathan Ko

Jonathan Ko

 cc: Social Capital Hedosophia Holdings Corp.

Chamath Palihapitiya

 cc: Shearman & Sterling LLP

Harald Halbhuber, Esq. and Ilir Mujalovic,
Esq.

Mail Stop 4720
June 21 , 2017

Chamath Palihapitiya
Chief Executive Officer
Social Capital Hedosophia Holdings Corp.
120 Hawthorne Avenue
Palo Alto, CA 94301

Re: Social Capital Hedosophia Holdings Corp.
Draft Registration Statement on Form S -1
Submitted  May 25 , 2017
CIK No . 0001706946

Dear  Mr. Palihapitiya :

We have reviewed your draft registration statement  and 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 this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration stateme nt on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing the information you provide in response to these  comments  and your
amended draft registration statement or filed registration statement,  we may have additional
comments.

General

1. Please supplementally provide us with copies of all written communications, as defined
in Rule 405 under the Securities Act, that you, or an yone authorized to do so on your
behalf,  present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not  they retain copies of the communications.

Cover Page

2. We note your references here and throughout the prospectus to e quity -linked securities.
In an appropriate section of the filing, please describe such securities and how they may
be used.

 Chamath Palihapitiya
Social Capital Hedosophia Holdings Corp.
 June 21, 2017
 Page 2

 Proposed Business

Our Partnership , page 72

3. We note your reference to Social Capital’s “strong investment track record.”  Please
briefly describe in more detail Social Capital’s track record.

Shareholders may not have the ability to approve our initial business combination, page 80

4. We note your disclosure on page 80 regarding whether shareholder approval would be
required under NASDAQ’s listing standards in certain instances.  Please also discuss
whether stockholder approval is currently required under the Companies Law, Cayman
Islands law or other applicable law.

You may contact  Cara Lubit, Staff Accountant,  at 202 -551-5909 or Hugh West ,
Accounting Branch Chief,  at 202 -551-3872  if you have questions regarding comments on the
financial statements and related matters. Please contact Jessica Livingston , Staff Attorney,  at
202-551-3448 or me at 202 -551-3391  with any other que stions.

Sincerely,

/s/ Erin E. Martin

          Erin E. Martin
          Special Counsel
Office of Financial Services

cc:  Howard L. Ellin , Esq.