Opendoor Technologies Inc.

1 Post Street, Floor 11
San Francisco, California 94104

January 21, 2021




Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

100 F Street, N.E.

Washington, D.C. 20549


Re:        Opendoor Technologies Inc.

Registration Statement on Form S-1

Filed January 14, 2021

File No. 333-251529



To whom it may concern:


Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, Opendoor Technologies Inc. (the “Company”) hereby respectfully requests that the effective date of the Company’s Registration Statement on Form S-1 (File No. 333-251529) be accelerated by the Securities and Exchange Commission to 4:00 p.m. Washington D.C. time on January 22, 2021 or as soon as practicable thereafter.


* * * *




The Company requests that we be notified of such effectiveness by a telephone call to Rachel Sheridan of Latham & Watkins LLP at (202) 637-2139 or to Shagufa Hossain of Latham & Watkins LLP at (202) 637-2323 and that such effectiveness also be confirmed in writing.


  Very truly yours,
  Carrie Wheeler
  /s/ Carrie Wheeler
  Name: Carrie Wheeler
  Title:   Chief Financial Officer



cc:          Elizabeth Stevens, Head of Legal, Opendoor Technologies Inc.

Rachel W. Sheridan, Latham & Watkins LLP

Shagufa Hossain, Latham & Watkins LLP