SPCE Virgin Galactic

Filed: 24 Jun 21, 8:00pm

Virgin Galactic Holdings, Inc.
166 North Roadrunner Parkway, Suite 1C
Las Cruces, New Mexico 88011

June 25, 2021

United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-6010
Attention: Irene Barberena-Meissner; Kevin Dougherty

Re:Virgin Galactic Holdings, Inc.
Registration Statement on Form S-3, as amended
File No. 333-256607

Ladies and Gentlemen:

In accordance with Rule 461 of Regulation C of the General Rules and Regulations under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on Form S-3 initially filed on May 28, 2021 (as amended, the “Registration Statement”) of Virgin Galactic Holdings, Inc. (the “Company”). We respectfully request that the Registration Statement become effective as of 4:00 p.m. Eastern Time on June 29, 2021, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Drew Capurro at (714) 755-8008.

Thank you for your assistance in this matter.

Very truly yours,


/s/ Michelle Kley
Michelle Kley
Executive Vice President,
General Counsel and Secretary

cc: Michael Colglazier, Virgin Galactic Holdings, Inc.
Drew Capurro, Latham & Watkins LLP
Justin G. Hamill, Latham & Watkins LLP