August 3, 2018

Jerre Stead
Chief Executive Officer
Churchill Capital Corp
640 Fifth Avenue, 12th Floor
New York, NY 10019

       Re: Churchill Capital Corp
           Draft Registration Statement on Form S-1
           Submitted July 11, 2018
           CIK No. 0001744895

Dear Mr. Stead:

       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
statement 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.

Draft Registration Statement on Form S-1 submitted July 11, 2018

General

1.     Prior to printing and distribution of the preliminary prospectus, please
provide us mock-
       ups of any pages that include any additional pictures or graphics to be
presented.
       Accompanying captions, if any, should also be provided. We may have
comments after
       reviewing the materials.
 Jerre Stead
Churchill Capital Corp
August 3, 2018
Page 2


2.       Please supplementally provide us with copies of all written
communications, as defined in
         Rule 405 under the Securities Act, that you, or anyone 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.
Risk Factors
We may amend the terms of the warrants in a manner that may be adverse to
holders of public
warrants, page 58

3.       Please revise to disclose the percentage of warrants that your initial
stockholders will own
         upon consummation of your initial business combination.
Signatures, page II-8

4.       Please revise the second half of your signature page to annotate that
the registration
         statement will be signed by your principal financial officer and your
controller or principal
         accounting officer. To the extent the listed signatories are also
signing in the
         aforementioned capacities, please revise to clarify. Refer to
Instruction 1 to Signatures on
         Form S-1.
        You may contact Amy Geddes at 202-551-3304 or Melissa Raminpour at
202-551-3379
if you have questions regarding comments on the financial statements and
related
matters. Please contact Donald Field at 202-551-3680 or Anne Parker at (202)
551-3611 with
any other questions.

FirstName LastNameJerre Stead
Comapany NameChurchill Capital Corp
                                                               Division of
Corporation Finance
August 3, 2018 Page 2                                          Office of
Transportation and Leisure
FirstName LastName