Paul, Weiss, Rifkind, Wharton & Garrison LLP

1285 Avenue of the Americas

New York, NY 10019-6064


May 3, 2019






Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549


  Re: Churchill Capital Corp II


    Registration Statement on Form S-1


Ladies and Gentlemen:


On behalf of our client, Churchill Capital Corp II, a Delaware corporation (the “Company”), we confidentially submit a draft registration statement on Form S-1 (the “Registration Statement”) for an underwritten offering of Units consisting of common stock and warrants. The Registration Statement is confidentially submitted pursuant to Title I, Section 106 under the Jumpstart Our Business Startups Act, as amended, for non-public review by the staff of the Securities and Exchange Commission prior to the public filing of the Registration Statement.


Any questions or notifications with respect to this letter should be directed to the undersigned at (212) 373-3309 or Katherine Shaia at (212) 373-3329.


  Very truly yours,
  /s/ Raphael M. Russo
  Raphael M. Russo



Peter Seibold
Churchill Capital Corp II

Joel L. Rubinstein, Esq.

Winston & Strawn LLP