September 3, 2019

Chamath Palihapitiya
Chief Executive Officer
Social Capital Hedosophia Holdings Corp.
120 Hawthorne Avenue
Palo Alto, CA 94301

       Re: Social Capital Hedosophia Holdings Corp.
           Registration Statement on Form S-4
           Filed August 7, 2019
           File No. 333-233098

Dear Mr. Palihapitiya:

       We have reviewed your registration statement and have the following
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.

Registration Statement on Form S-4 filed August 7, 2019

Prospectus Summary, page 1

1.     Please revise to provide the dates of the U.S. Chamber of Commerce
article you cite here
       and the Credit Suisse Research Institute report you cite on page 201.
2.     Please disclose your expected timeline of achieving and the substance of
your remaining
       verification and validation steps that must be completed before the FAA
will clear you to
       include customers on your spaceflights.
 Chamath Palihapitiya
FirstName LastNameChamath Palihapitiya
Social Capital Hedosophia Holdings Corp.
Comapany 3, 2019
September NameSocial Capital Hedosophia Holdings Corp.
September 3, 2019 Page 2
Page 2
FirstName LastName
Risk Factors
Risks Related to VGH, Inc.'s Business
Due to the inherent risks associated with commercial spaceflight..., page 37

3.       Please disclose your conclusions about and steps you have taken to
address the causes of
         the October 31, 2014 in-flight incident.
Risks Related to the Consummation of the Domestication
The provisions of the proposed certificate of incorporation requiring exclusive
forum in the
Court of Chancery of the State of Delaware..., page 71

4.       You disclose here and elsewhere that your certificate of incorporation
includes a forum
         selection provision identifying the Court of Chancery of the State of
Delaware as the
         exclusive forum for certain litigation, including any "derivative
action," but that,
         notwithstanding this provision, your proposed certificate of
incorporation will provide that
         the exclusive forum provision will not apply to suits brought to
enforce a duty or liability
         created by the Securities Act or the Exchange Act or any other claim
for which the federal
         courts have exclusive jurisdiction. However, your form of Certificate
of Incorporation
         included as Annex F does not include this limitation. If this
provision does not apply to
         actions arising under the Securities Act or Exchange Act, please
ensure that the exclusive
         forum provision in your Certificate of Incorporation states this
clearly.
Background to the Business Combination, page 111

5.       We note your disclosure that the initial non-binding letter SCH sent
to Virgin management
         on January 24, 2019 included an initial enterprise value for the
Virgin Galactic business
         operated by the VG Companies and the Virgin Orbit business of $1.5
billion on a pre-
         transaction, debt-free, cash-free basis. After the Virgin Orbit
business was excluded, on
         March 2, 2019, you further disclose that SCH sent to Virgin management
the first version
         of a new non-binding letter of intent, and that this $850 million
(with no earn-out
         opportunity) and a secondary repurchase of up to $150 million
valuation fell within the
         lower range of valuations that SCH management had considered for the
VG Companies
         alone. Please revise to provide additional details regarding how SCH
determined the
         valuation of the Virgin businesses initially and then the range of
valuations for the VG
         Companies alone.
Projected Financial Information, page 128

6.       We note your disclosure regarding the financial projections provided
by management of
         the VG Companies to SCH. Please disclose, and quantify as appropriate,
the material
         assumptions underlying these projections. For example, we note that
the projected
         financial summary on slide 61 from the investor presentation filed on
an Exhibit 99.2 to a
         Form 8-K, Rule 425 filing, filed on July 9, 2019 includes assumptions
as to the numbers
         of vehicles, total flights and total number of passengers, among other
assumptions
 Chamath Palihapitiya
FirstName LastNameChamath Palihapitiya
Social Capital Hedosophia Holdings Corp.
Comapany 3, 2019
September NameSocial Capital Hedosophia Holdings Corp.
September 3, 2019 Page 3
Page 3
FirstName LastName
         disclosed that appear to underlie the revenue projections.
U.S. Federal Income Tax Considerations, page 163

7.       You disclose that you intend the domestication will qualify as a
"reorganization" within
         the meaning of Section 368(a)(1)(F) of the Code. As such, a tax
opinion appears
         required. If you elect to use a short-form opinion, please note that
the opinion and the
         related tax disclosure in the prospectus both must state clearly that
the disclosure in the tax
         consequences section of the prospectus is the opinion of counsel and
that disclosure must
         clearly identify and articulate the opinion being rendered. Please
refer to Section III of
         Staff Legal Bulletin 19 (Oct. 14, 2011).
Unaudited Pro Forma Condensed Combined Financial Information, page 173

8.       Please tell us your consideration of reflecting the new trademark
license agreement
         granting the rights to use certain VIRGIN marks in the pro forma
financial statements
         pursuant to Item 11-02 of Regulation S-X.
Information About SCH
Directors and Executive Officers, page 188

9.       A number of the biographical sketches of your officers and directors
are unclear with
         regard to the most recent five years of business experience, including
positions held
         during that time. In particular, please revise the sketches for
Messrs. Williamsand Bain to
         eliminate any gaps or ambiguities regarding their experience during
the most recent five
         years. Please also disclose any other directorships held by them in
another public
         company during that timeframe. In this regard, we note that Mr.
Palihapitiya appears
         serve as a director of Slack Technologies Inc. See Item 401(e) of
Regulation S-K.
Facilities, page 216

10.      Please file copies of the lease agreements for your facilities at the
Mojave Air and Space
         Port in Mojave, California or explain why they are not required to be
filed. Refer to Item
         601(b)(10) of Regulation S-K.
The VG Companies Management's Discussion and Analysis of Financial Condition
and Results
of Operations
Funding Requirements, page 227

11.      We note that the VG Companies have two additional SpaceShipTwo
vehicles under
         construction to expand the fleet to a total of five SpaceShipTwo by
the end of 2023, in
         addition to expenditures related to the anticipated launch in 2020.
Please provide an
         estimate of the amount of capital necessary to accomplish these goals
as well as the timing
         of such costs. See Item 303(a)(2) of Regulation S-K.
 Chamath Palihapitiya
Social Capital Hedosophia Holdings Corp.
September 3, 2019
Page 4
Executive Compensation
Executive Compensation Arrangements, page 242

12.   Please file copies of your employment agreements with George T.
Whitesides, Michael
      Moses, and Enrico Palermo as exhibits. Refer to Item 601(b)(10)(iii)(A)
of Regulation S-
      K.
Virgin Galactic Business Financial Statements
Basis of Presentation, page F-31

13.   We note that the carve-out historical combined financial statements of
the Virgin Galactic
      Business do not reflect any attribution of debt or allocation of interest
expense. Please tell
      us your consideration of attributing debt or allocating interest expense
to the carve-out
      financial statements and the basis for your conclusion of your current
treatment.
Customer Deposits, page F-31

14.   Please provide an accounting policy for your treatment of customer
deposits, including the
      circumstances in which the deposits become nonrefundable.
        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.

        You may contact Theresa Brillant, Staff Accountant, at 202-551-3307, or
Andrew Mew,
Senor Assistant Chief Accountant, at 202-551-3377 if you have questions
regarding comments
on the financial statements and related matters. Please contact Irene
Barberena-Meissner, Staff
Attorney, at 202-551-6548 or Kevin Dougherty, Staff Attorney, at 202-551-3271
with any other
questions.



                                                             Sincerely,
FirstName LastNameChamath Palihapitiya
                                                      Division of Corporation
Finance
Comapany NameSocial Capital Hedosophia Holdings Corp.
                                                      Office of Transportation
and Leisure
September 3, 2019 Page 4
cc:       Howard Ellin
FirstName LastName