United States securities and exchange commission logo September 14, 2020 James A. Graf Chief Executive Officer Graf Industrial Corp. 118 Vintage Park Blvd., Suite W-222 Houston, TX 77070 Re: Graf Industrial Corp. Preliminary Merger Proxy Statement on Schedule 14A Filed July 15, 2020 File No. 001-38703 Dear Mr. Graf: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Technology cc: Joel L. Rubinstein