December 9, 2019

James J. Dolan
Chief Executive Officer
Gordon Pointe Acquisition Corp.
780 Fifth Avenue South
Naples, FL 34102

       Re: Gordon Pointe Acquisition Corp.
           Preliminary Proxy Statement on Schedule 14A
           Filed November 13, 2019
           File No. 001-38363

Dear Mr. Dolan:

       We have limited our review of your registration statement to those
issues we have
addressed in our comments. In some of our comments, we may ask you to provide
us with
information so we may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Preliminary Proxy Statement on Schedule 14A filed November 13, 2019

General

1.     We note that there is a concurrent S-4 filing by GPAQ Acquisition
Holdings, Inc., your
       wholly owned subsidiary, regarding the transaction disclosed in your
preliminary proxy
       statement. To the extent that any comments on the S-4 apply to your
preliminary proxy
       statement, please apply these comments to you preliminary proxy
statement and amend
       your disclosure accordingly, so that the disclosure in your proxy
statement is consistent
       with that in the S-4.
2.     Please unbundle the Charter Amendments Proposal into separate proposals
so as to allow
       shareholders to vote separately on material matters, or provide your
analysis as to why
       you believe you are not required to do so. Please refer to Rule
14a-4(a)(3) of Regulation
       14A, as well as Question 201.01 of the Division's Exchange Act Rule
14a-4(a)(3)
 James J. Dolan
Gordon Pointe Acquisition Corp.
December 9, 2019
Page 2
      Compliance and Disclosure Interpretations.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

      Please contact Katherine Bagley at (202) 551-2545 or Lilyanna Peyser at
(202) 551-
3222 with any questions.



                                                           Sincerely,
FirstName LastNameJames J. Dolan
                                                           Division of
Corporation Finance
Comapany NameGordon Pointe Acquisition Corp.
                                                           Office of Trade &
Services
December 9, 2019 Page 2
cc:        Stephen Cohen
FirstName LastName