United States securities and exchange commission logo January 21, 2021 Eric Wu Chief Executive Officer Opendoor Technologies Inc. 1 Post Street Floor 11 San Francisco, CA 94104 Re: Opendoor Technologies Inc. Draft Registration Statement on Form S-1 Submitted January 15, 2021 CIK No. 0001801169 Dear Mr. Wu: This is to advise you that we do not intend to review your registration statement. We request that you publicly file your registration statement no later than 48 hours prior to the requested effective date and time. 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 Stacie Gorman at 202-551-3585 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Rachel W. Sheridan, Esq.