December 17, 2018

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

       Re: DiamondPeak Holdings Corp.
           Draft Registration Statement on Form S-1
           Submitted on November 21, 2018
           CIK No. 0001759546

Dear Mr. Hamamoto:

       We have reviewed your draft registration statement 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 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 comments apply 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 these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-1

Description of Securities
Exclusive forum for certain lawsuits, page 113

1.     We note that the exclusive forum provision in your amended and restated
certificate of
       incorporation will identify the Court of Chancery in the State of
Delaware as the exclusive
       forum for certain litigation, including any "derivative actions." Please
disclose whether
       this provision will apply to actions arising under the Securities Act or
Exchange Act. In
       this regard, we note that Section 27 of the Exchange Act creates federal
jurisdiction over
       all suits brought to enforce any duty or liability created by the
Exchange Act or the rules
       and regulations thereunder. If this provision does not apply to actions
arising under the
 David T. Hamamoto
DiamondPeak Holdings Corp.
December 17, 2018
Page 2
         federal securities laws, please ensure that the exclusive forum
provision in your amended
         and restated certificate of incorporation states this clearly.
General

2.       Please provide us with copies of all written communications, as
defined in Rule 405 under
         the Securities Act, that you, or anyone authorized to do so on your
behalf, present to
         potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they
         retain copies of the communications.
       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 202-551-3469 with any other
questions.



FirstName LastNameDavid T. Hamamoto                           Sincerely,
Comapany NameDiamondPeak Holdings Corp.
                                                              Division of
Corporation Finance
December 17, 2018 Page 2                                      Office of
Transportation and Leisure
FirstName LastName