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                              July 16, 2020

       Martin McNulty, Jr.
       Chief Executive Officer
       Starboard Value Acquisition Corp.
       777 Third Avenue, 18th Floor
       New York, New York 10017

                                                        Re: Starboard Value
Acquisition Corp.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted June 23,
2020
                                                            CIK 0001794905

       Dear Mr. McNulty:

              We have reviewed your draft registration statement and have the
following comment. In
       our comment, 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 comment applies 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 this
comment and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Draft Registration Statement on Form S-1 submitted June 23, 2020

       The Offering, page 15

   1.                                                   We note disclosure in
your Risk Factor section indicates that there may be instances
                                                        wherein public
shareholders may receive less than $10.00 per share upon redemption.
                                                        Please revise your
disclosure on pages 27, 106 and 114 to clarify that there is no guarantee
                                                        that investors may
receive $10.00 per share upon redemption.
 Martin McNulty, Jr.
FirstName  LastNameMartin
                Acquisition McNulty, Jr.
Starboard Value             Corp.
Comapany
July       NameStarboard Value Acquisition Corp.
     16, 2020
July 16,
Page  2 2020 Page 2
FirstName LastName
       You may contact Jeffrey Lewis at 202-551-6216 or Wilson Lee at
202-551-3468 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jonathan Burr at 202-551-5833 or Erin E. Martin at 202-551-3391 with
any other
questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Real Estate &
Construction