Giovanni Caruso



345 Park Avenue
New York, NY 10154



Direct     212.407.4866
Main       212.407.4000
Fax         212.937.3943


Via Edgar


December 1, 2020


David Link
Division of Corporation Finance
Office of Real Estate & Construction
U.S. Securities & Exchange Commission

100 F Street, NE

Washington, D.C. 20549



Ventoux CCM Acquisition Corp.
Amendment No. 1 to

Draft Registration Statement on Form S-1
Submitted September 29, 2020
CIK 0001822145


Dear Mr. Link:


On behalf of our client, Ventoux CCM Acquisition Corp. (the “Company”), we hereby provide a response to the comment issued in a letter dated October 14, 2020 (the “Staff’s Letter”) regarding the Company’s Amendment No. 1 to Draft Registration Statement on Form S-1 (the “Registration Statement”). Contemporaneously, we are submitting the amended Registration Statement via Edgar (the “Amended S-1”).


In order to facilitate the review by the Commission’s staff (the “Staff”) of the Amended S-1, we have responded, on behalf of the Company, to the comment set forth in the Staff’s Letter below. The numbered paragraph set forth below responds to the Staff’s comment and corresponds to the numbered paragraph in the Staff’s Letter.





Los Angeles      New York     Chicago     Nashville     Washington, DC     Beijing     Hong Kong


A limited liability partnership including professional corporations




David Link
December 1, 2020

Page 2


Draft Registration Statement on Form S-1 submitted September 29, 2020





We note your response to comment 1. Please revise your cover page to provide prominent

disclosure of the fact you may require stockholders to vote for or against the business

combination to be able to redeem their shares and that stockholders who do not vote, or

who abstain from voting, on the business combination will not be able to redeem their

shares. Also address this fact in the relevant discussions regarding redemption rights

throughout the prospectus.


Response: The Company has revised the cover page and the disclosure on pages 25, 28, 46, 63 and 91 in accordance with the Staff’s comments.


Please call me at 212 407-4866 if you would like additional information with respect to any of the foregoing. Thank you.





/s/ Giovanni Caruso 

Giovanni Caruso