United States securities and exchange commission logo

                                September 17, 2020

       David Hamamoto
       Chairman and Chief Executive Officer
       DiamondPeak Holdings Corp.
       40 W. 57th Street, 29th Floor
       New York, New York 10019

                                                        Re: DiamondPeak
Holdings Corp.
                                                            Preliminary Proxy
Statement on Schedule 14A
                                                            Filed August 24,
                                                            File No. 001-38821

       Dear Mr. Hamamoto:

              We have reviewed your filing 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

              Please respond to these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Schedule 14A filed on August 24, 2020


   1.                                                   We note the Investor
Presentation available on Lordstown's website. Please revise your
                                                        filing to ensure
consistency with the disclosure provided in the presentation. For example,
                                                        the slides appear to
contain a more detailed breakdown to support the claim that your
                                                        vehicle has a lower
cost of ownership than your competitors.
       Table of Contents, page i

   2.                                                   Please revise the table
of contents to add a list of the annexes that are attached to the
                                                        proxy materials.
 David Hamamoto
FirstName LastNameDavid   Hamamoto
DiamondPeak   Holdings Corp.
Comapany 17,
September NameDiamondPeak
              2020           Holdings Corp.
Page 2    17, 2020 Page 2
FirstName LastName
Questions and answers about the proposal for DiamondPeak stockholders, page 1

3.       Please add a question and answer that addresses the factors that the
board considered in
         determining to enter into the merger agreement and its rationale for
approving the
         transaction. Disclose a brief summary of the material positive and
negative factors that
         the board considered in approving the transaction.
Risk Factors
Risks Related to Lordstown   s Business Operations and Industry, page 38

4.       We note that Lordstown's independent auditor has raised substantial
doubt about its ability
         to continue as a going concern. Please add a corresponding discussion
in Risk Factors.
Proposal Number 2 - The Charter Proposal, page 124

5.       We note that you plan to amend your charter to make such other changes
that the
         DiamondPeak Board deems appropriate for a public operating company.
Please identify
         all of the amendments proposed to be made to your charter, the reasons
for and the general
         effect of such amendment in the proxy statement. For example, we note
that your second
         amended and restated certificate of incorporation includes a revised
exclusive forum
Business of Lordstown, page 161

6.       Please expand this section to include the information required, to the
         necessary, under Items 101(h)(v) and (vii) of Regulation S-K.
Lordstown's Product, page 162

7.       We note your disclosure on page 163 that Lordstown expects the total
cost of ownership
         of the Endurance to be significantly lower than the total cost of
ownership of internal
         combustion engine and diesel-fueled pickup trucks, and that the
Endurance will have
         500% better fuel economy. Please expand your disclosure to provide the
         relied upon for your estimates.
        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.
 David Hamamoto
DiamondPeak Holdings Corp.
September 17, 2020
Page 3

       You may contact Effie Simpson, Staff Accountant, at (202) 551-3346 or
Raminpour, Accounting Branch Chief, at (202) 551-3379 if you have questions
comments on the financial statements and related matters. Please contact Sergio
Chinos, Staff
Attorney, at (202) 551-7844 or Erin Purnell, Staff Attorney, at (202) 551-3454
with any other

FirstName LastNameDavid Hamamoto                           Sincerely,
Comapany NameDiamondPeak Holdings Corp.
                                                           Division of
Corporation Finance
September 17, 2020 Page 3                                  Office of
FirstName LastName