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                          March 7, 2023

       Thomas Fennimore
       Chief Financial Officer
       Luminar Technologies, Inc./DE
       2603 Discovery Drive, Suite 100
       Orlando, Florida 32826

                                                        Re: Luminar
Technologies, Inc./DE
                                                            Registration
Statement on Form S-4
                                                            Filed March 1, 2023
                                                            File No. 333-270152

       Dear Thomas Fennimore:

              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 Eranga
Dias at 202-551-8107 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Manufacturing