United States securities and exchange commission logo August 16, 2021 David M. Kastin, Esq. General Counsel Clever Leaves Holdings Inc. 489 Fifth Avenue, 27th Floor New York, NY 10017 Re: Clever Leaves Holdings Inc. Draft Registration Statement on Form S-1 Submitted August 10, 2021 CIK No. 0001819615 Dear Mr. Kastin: This is to advise you that we do not intend to review your registration statement. We request that you publicly file your registration statement no later than 48 hours prior to the requested effective date and time. 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 David Gessert at 202-551-2326 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences