0001144204-18-053785.txt : 20181113 0001144204-18-053785.hdr.sgml : 20181113 20181015122133 ACCESSION NUMBER: 0001144204-18-053785 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20181015 FILER: COMPANY DATA: COMPANY CONFORMED NAME: Graf Industrial Corp. CENTRAL INDEX KEY: 0001745317 STANDARD INDUSTRIAL CLASSIFICATION: BLANK CHECKS [6770] IRS NUMBER: 000000000 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 118 VINTAGE PARK BLVD STREET 2: SUITE W-222 CITY: HOUSTON STATE: TX ZIP: 77070 BUSINESS PHONE: 3107458669 MAIL ADDRESS: STREET 1: 118 VINTAGE PARK BLVD STREET 2: SUITE W-222 CITY: HOUSTON STATE: TX ZIP: 77070 CORRESP 1 filename1.htm

EARLYBIRDCAPITAL, INC.

366 Madison Avenue | 8th Floor

New York, NY 10017

October 15, 2018

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate and Commodities

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attention:

Erin E. Martin

Sarah von Althann

Re:

Graf Industrial Corp.

Registration Statement on Form S-1

File No. 333-227396

Dear Ms. Martin:

In connection with the Registration Statement on Form S-1 of Graf Industrial Corp., the undersigned, which is acting as the representative of the underwriters of the offering, hereby requests acceleration of the effective date and time of the Registration Statement to 4:00 p.m. on Monday, October 15, 2018 or as soon thereafter as practicable, pursuant to Rule 461 of the Securities Act of 1933, as amended (the “Act”).

Pursuant to Rule 460 of the General Rules and Regulations under the Act, the undersigned advises that as of the date hereof, 426 copies of the Preliminary Prospectus dated October 10, 2018 have been distributed to prospective underwriters, dealers, institutional investors, retail investors and others.

The undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities and Exchange Act of 1934, as amended.

	Very truly yours,

	EARLYBIRDCAPITAL, INC.

	By:	/s/ Steven Levine
		Name: Steven Levine
		Title: CEO