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                             December 1, 2020

       Tong Chen
       Chief Executive Officer
       Primavera Capital Acquisition Corp.
       41/F Gloucester Tower
       15 Queen   s Road Central
       Hong Kong

                                                        Re: Primavera Capital
Acquisition Corp.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted November
16, 2020
                                                            CIK No. 0001818787

       Dear Mr. Chen:

              We have reviewed your amended draft registration statement and
have the following
       comment. In our comment, we may ask you to provide us with information
so we may better
       understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comment applies to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to this
comment and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Draft Registration Statement on Form S-1

       General

   1.                                                   Please describe clearly
the terms of issuance of the 2,000,000 shares in September 2020
                                                        including to whom they
were issued and any conditions relating to their issuance, such as
                                                        being in contemplation
of one or more forward purchase agreements or backstop
                                                        arrangements. Also,
clarify your statement that these securities "will be forfeited in
                                                        connection with the
closing of this offering to the extent we do not do so." Revise the
                                                        disclosure throughout
your prospectus to reflect this issuance, as applicable. If your
                                                        founder shares would
represent more than 20% of the outstanding shares after this
                                                        offering please state
that clearly. We may have further comment.
 Tong Chen
Primavera Capital Acquisition Corp.
December 1, 2020
Page 2

      You may contact Ruairi Regan at 202-551-3269 or Maryse Mills-Apenteng at
202-551-
3457 with any questions.



                                                       Sincerely,
FirstName LastNameTong Chen
                                                       Division of Corporation
Finance
Comapany NamePrimavera Capital Acquisition Corp.
                                                       Office of Real Estate &
Construction
December 1, 2020 Page 2
cc:       Deanna L. Kirkpatrick, Esq.
FirstName LastName