United States securities and exchange commission logo





                            January 22, 2021

       Vivek Garipalli
       Chief Executive Officer
       Clover Health Investments, Corp.
       725 Cool Springs Blvd, Suite 320
       Franklin, TN 37067

                                                        Re: Clover Health
Investments, Corp.
                                                            Registration
Statement on Form S-1
                                                            Filed January 13,
2021
                                                            File No. 333-252073

       Dear Mr. Garipalli:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Julia
Griffith at 202-551-3267 with any questions.




                            Sincerely,


                            Division of Corporation Finance

                            Office of Finance
       cc:                                              Niki Fang