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                               December 5, 2023

       Christina Schwartz
       Interim Chief Financial Officer
       Opendoor Technologies Inc.
       410 N. Scottsdale Road, Suite 1600
       Tempe, AZ 85288

                                                        Re: Opendoor
Technologies Inc.
                                                            Form 10-K for the
year ended December 31, 2022
                                                            Form 10-Q for the
quarterly period ended September 30, 2023
                                                            File No. 001-39253

       Dear Christina Schwartz:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K for the year ended December 31, 2022

       Item 7. Management   s Discussion and Analysis of Financial Condition
and Results of
       Operations
       Financial Highlights, page 40

   1.                                                   Please revise future
filings both here and throughout your filing, as applicable, to label all
                                                        non-GAAP measures as
such and to provide a cross-reference to your discussion and
                                                        reconciliations of such
non-GAAP measures to their nearest comparable GAAP
                                                        measures.
       Inventory Management, page 42

   2.                                                   Given the significance
of sell-through rates, holding periods and portfolio aging to your
                                                        business, please tell
us what consideration you have given to disclosing these metrics in a
                                                        format, such as a
tabular presentation, that would enable a reader to see how movements
                                                        between each of these
metrics impacted your business in each of the periods presented.
                                                        For instance, we note
your discussion on page 30 of the effects that aging of the portfolio
 Christina Schwartz
Opendoor Technologies Inc.
December 5, 2023
Page 2
         has on your ability to finance homes; however, it is not readily
apparent what effect
         portfolio aging had on your ability to finance homes and on cash as
collateral in the
         periods presented.
Adjusted EBIDTA Margin , page 46

3.       Please revise future filings to disclose how you calculate adjusted
EBITDA margin.
Form 10-Q for the quarterly period ended September 30, 2023

Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Liquidity and Capital Resources
Overview, page 41

4.       Please tell us what consideration you gave to enhancing your
disclosure regarding the
         nature of your increase in restricted cash during the period,
including but not limited to the
         amount of the increase that relates to the requirement to pledge
additional cash as
         collateral for properties you have owned for extended periods. In
addition, we note your
         disclosure on page 41 that states, "[t]he increase in our restricted
cash balance of $570
         million as compared to December 31, 2022 was a result of the proactive
reduction of our
         acquisition pace via higher spreads embedded in our offers and lower
marketing
         investment, resulting in greater restricted cash available for the
future acquisition of real
         estate inventory." Please clarify for us how this assertion is
representative of the increase
         in restricted cash during the period.
       In closing, 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 Paul Cline at 202-551-3851 or Jennifer Monick at
202-551-3295 with any
questions.



FirstName LastNameChristina Schwartz                            Sincerely,
Comapany NameOpendoor Technologies Inc.
                                                                Division of
Corporation Finance
December 5, 2023 Page 2                                         Office of Real
Estate & Construction
FirstName LastName