United States securities and exchange commission logo November 13, 2020 Ophir Sternberg Chief Executive Officer Opes Acquisition Corp. 4218 NE 2nd Avenue Miami, FL 33137 Re: Opes Acquisition Corp. Amendment No. 2 to Preliminary Proxy Statement on Schedule 14A Filed November 6, 2020 File No. 001-38417 Dear Mr. Sternberg: We have reviewed your filing 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 our comment 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 our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to our comment, we may have additional comments. PRER14A Filed November 6, 2020 Financial Statements, page F-1 1. Please update the financial statements in accordance with the Instructions to Item 14 of Schedule 14A. Ophir Sternberg FirstName LastNameOphir Sternberg Opes Acquisition Corp. Comapany 13, November NameOpes 2020 Acquisition Corp. November Page 2 13, 2020 Page 2 FirstName LastName 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. You may contact Aamira Chaudhry at 202-551-3389 or Angela Lumley at 202-551-3398 if you have questions regarding comments on the financial statements and related matters. Please contact Scott Anderegg at 202-551-3342 or Lilyanna Peyser at 202-551-3222 with any other questions. Sincerely, Division of Corporation Finance Office of Trade & Services