United States securities and exchange commission logo

                             January 5, 2021

       Thomas Fennimore
       Chief Financial Officer
       Luminar Technologies, Inc./DE
       2603 Discovery Drive, Suite 100
       Orlando, Florida 32826

                                                        Re: Luminar
Technologies, Inc./DE
Statement on Form S-1
                                                            Filed December 23,
                                                            File No. 333-251657

       Dear Mr. Fennimore:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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 and
       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.

       Registration Statement on Form S-1


   1.                                                   We note your
registration statement covers the offer and sale by you of up to
                                                        6,666,666 shares of
Class A Stock that are issuable upon the exercise of 6,666,666
                                                        warrants that appear to
have been immediately exercisable when issued privately. Please
                                                        note that a transaction
that commenced privately cannot be converted to a registered
                                                        offering. Please revise
the registration statement to remove the primary issuance of up to
                                                        6,666,666 shares of
Class A Stock or tell us why the warrants were not immediately
                                                        exercisable when
issued. Refer to Question 134.02 of our Securities Act Sections
                                                        Compliance and
Disclosure Interpretations.
 Thomas Fennimore
Luminar Technologies, Inc./DE
January 5, 2021
Page 2
Executive Compensation, page 112

2.       Please update your executive compensation disclosure to reflect the
last completed fiscal
         year. Refer to Item 402(c) of Regulation S-K.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration

       Please contact Erin Purnell at 202-551-3454 or Jay Ingram at
202-551-3397 with any

FirstName LastNameThomas Fennimore                            Sincerely,
Comapany NameLuminar Technologies, Inc./DE
                                                              Division of
Corporation Finance
January 5, 2021 Page 2                                        Office of
FirstName LastName