February 20, 2019

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

       Re: DiamondPeak Holdings Corp.
           Amendment No. 2 to Registration Statement on Form S-1
           Filed February 14, 2019
           File No. 333-229286

Dear Mr. Hamamoto:

      We have reviewed your amended registration statement and have the
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
circumstances or do not believe an amendment is appropriate, please tell us why
in your

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our December 17,
2018 letter.

Amendment No. 2 to Registration Statement on Form S-1

Description of Securities
Exclusive forum for certain lawsuits, page 136

1.     We note your response to our prior comment 1 and we reissue in part.
Please revise your
       exclusive forum provision and your disclosure to clarify whether your
exclusive forum
       provision will apply to actions arising under the Exchange Act. In that
regard, we note
       that your exclusive forum provision refers to "any action arising under
the federal
       securities laws, as to which the Court of Chancery and the federal
district court for the
       District of Delaware shall have concurrent jurisdiction." We also note
that Section 27 of
       the Exchange Act creates exclusive federal jurisdiction over all suits
brought to enforce
 David T. Hamamoto
DiamondPeak Holdings Corp.
February 20, 2019
Page 2
         any duty or liability created by the Exchange Act or the rules and
regulations thereunder.
       You may contact Amy Geddes at (202) 551-3304 or Jean Yu at (202)
551-3305 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Susan Block at (202) 551-3210 or Justin Dobbie at (202) 551-3469 with
any other

FirstName LastNameDavid T. Hamamoto                           Sincerely,
Comapany NameDiamondPeak Holdings Corp.
                                                              Division of
Corporation Finance
February 20, 2019 Page 2                                      Office of
Transportation and Leisure
FirstName LastName