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                                                             December 23, 2019

Lloyd Carney
Chief Executive Officer
ChaSerg Technology Acquisition Corp
7660 Fay Avenue, Suite H, Unit 339
La Jolla, CA 92037

       Re: ChaSerg Technology Acquisition Corp
           Preliminary Proxy Statement on Schedule 14A
           Filed November 27, 2019
           File No. 001-38685

Dear Mr. Carney:

       We have reviewed your filing 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Preliminary Proxy Statement on Schedule 14A

Letter to Shareholders, page i

1.     We encourage you revise the forepart of the proxy statement so that it
describes the
       business combination transaction, its purpose and its effect in plain
English rather reciting
       the complex and technical details of the merger transactions. Similarly,
please explain the
       reasons why the cash and stock components of the merger consideration
can be adjusted,
       as this will allow shareholders to better understand how the adjustments
will operate and
       the circumstances that could lead to the adjustments.
2.     Prominently highlight throughout the proxy statement that the
acquisition of Grid
       Dynamics is an affiliated transaction because ChaSerg's President and
Chief Financial
       Officer, Eric Benhamou, is a director on both companies' boards and has
direct and
       indirect ownership interests in both companies.
 Lloyd Carney
FirstName LastNameLloyd Carney
ChaSerg Technology Acquisition Corp
Comapany23, 2019
December NameChaSerg Technology Acquisition Corp
Page 2
December 23, 2019 Page 2
FirstName LastName
Cautionary Note Regarding Forward-Looking Statements, page 4

3.       You disclose that the proxy statement includes forward-looking
statements within the
         meaning of Section 27A of the Securities Act of 1933 and Section 21E
of the Securities
         Exchange Act of 1934. Section 27A(b)(1)(B) of the Securities Act and
Section
         21E(b)(1)(B) of the Exchange Act expressly state that the safe harbor
for forward-looking
         statements is not available in connection with an offering of
securities by a blank check
         company. Please delete the references to these safe harbor provisions
or clarify that they
         do not apply to your company.
Question and Answers About the Proposals for Stockholders, page 5

4.       Please provide a Q&A describing what will happen if more than the
maximum number of
         shares allowed for by the conditions to the Merger Agreement are
redeemed. In this
         regard, you state on page 51 that if a larger number of shares are
submitted for redemption
         than you initially expected, you may need restructure the transaction
to reserve a greater
         portion of the cash in the Trust Account or arrange for third-party
financing.
Summary of the Proxy Statement
Parties to the Business Combination, page 14

5.       Please disclose that Grid Dynamics is currently majority owned by
Automated Systems
         Holding Limited, a publicly traded Bermuda company on the Hong Kong
Exchange that is
         a subsidiary of Beijing Teamsun Technology Co., Ltd., a publicly
traded Chinese
         company on the Shanghai Stock Exchange. Disclose that Grid Dynamics
was acquired by
         ASL in April 2017.
6.       Please consider providing organizational charts of ChaSerg and Grid
Dynamics before and
         after the business combination in light of the current ownership of
Grid Dynamics, the
         ownership of the Successor after the business combination and the
control over the
         Successor company by Sponsor, ASL, BGV and other parties to the
Stockholders'
         Agreement.
Conditions to Closing of the Business Combination, page 15

7.       We note that each party's obligations are subject to the satisfaction
or written waiver by
         the parties of the listed conditions. Please disclose whether the
parties can waive the
         maximum redemption condition under the merger agreement that leaves
ChaSerg with
         70% of the Trust Account Balance at Signing. If so, revise your
disclosure throughout the
         proxy statement so that it also contemplates a maximum redemption
amount that leaves
         ChaSerg with at least $5,000,001 in tangible net assets in the Trust
Account. Also
         disclose how you will inform each company's stockholders if this
condition is waived.
 Lloyd Carney
FirstName LastNameLloyd Carney
ChaSerg Technology Acquisition Corp
Comapany23, 2019
December NameChaSerg Technology Acquisition Corp
Page 3
December 23, 2019 Page 3
FirstName LastName
Interests of Certain Persons in the Business Combination, page 18

8.       Please provide quantified disclosure of Eric Benhamou's interest in
the business
         combination as a director and shareholder in each party. Also disclose
that Mr.
         Benhamou's affiliate, BGV Opportunity Fund, L.P. made a $15 million
investment in
         common and preferred stock in Grid Dynamics in May 2019. Disclose the
value of the
         merger consideration he will receive for this investment.
Risk Factors
Grid Dynamics' revenues are highy dependent on a limited number of clients...,
page 27

9.       Please disclose the dollar amount of backlog believed to be firm,
separately
         indicating the portion thereof not expected to be filled within the
current year. Refer to
         Item 101(c)(1)(viii) of Regulation S-K.
Material weakness has been identified in Grid Dynamics' internal control over
financial
reporting, page 31

10.      Please expand your disclosures to describe the steps that Grid
Dynamics is currently
         taking to enhance its internal control environment and the additional
steps they plan on
         taking to remediate the identified material weakness.
Provisions in our amended and restated certificate of incorporation and
Delaware law..., page 49

11.      You state that your amended and restated certificate of incorporation
will provide for a
         staggered board of directors. Please enhance this risk factor by also
disclosing that
         directors may be removed from office by the stockholders only for
cause and that the
         board of directors will have the exclusive right to fill any vacancy
resulting from
         removal. Also, provide a cross-reference to the corresponding
disclosure on pages 108
         and 192.
Unaudited Pro Forma Condensed Combined Financial Information
Notes to Unaudited Pro Forma Condensed Combined Financial Information, page 59

12.      You state that the income tax adjustments in note (CC) reflect the tax
impact on the pro
         forma adjustments at the estimated statutory tax rate of 28%. Please
explain how you
         determined the pro forma tax expense. In this regard, we note that
Grid Dynamics had a
         statutory tax rate of 21% for 2018 and there is a significant
difference in the historical
         effective tax rates for the periods presented in the pro forma
statements of income.
13.      Please tell us why your calculation of pro form weighted shares
outstanding excludes
         1,200,000 Sponsor Shares that are held in escrow. In this regard, you
state that while such
         shares are in escrow, the Sponsor shall have full ownership rights,
including the right to
         vote such shares and receive dividends and distributions thereon.
Therefore, tell us how
         you considered the guidance in ASC 260-10-45-59A   60A in your pro
forma per share
         calculations.
 Lloyd Carney
FirstName LastNameLloyd Carney
ChaSerg Technology Acquisition Corp
Comapany23, 2019
December NameChaSerg Technology Acquisition Corp
Page 4
December 23, 2019 Page 4
FirstName LastName
Background of the Business Combination, page 82

14.      Given the affiliated nature of the transaction through Eric Benhamou's
board seats and
         ownership interests in both ChaSerg and Grid Dynamics, provide a more
detailed
         discussion regarding ChaSerg's efforts to find targets, contacts with
other potential
         candidates and discussions held with potential targets. Disclose the
general business of
         the potential targets, the extent of negotiations and whether the
board considered a merger
         with any of the targets a viable alternative to a transaction with
Grid Dynamics. Disclose
         when and why each target was rejected in favor of a transaction with
Grid Dynamics.
         Disclose when ChaSerg determined to negotiate exclusively with Grid
Dynamics.
15.      You disclose that, on November 19, 2018, Mr. Benhamou facilitated an
introductory
         meeting between advisors of ChaSerg and Grid Dynamics' chief executive
officer and
         board member to discuss a potential business transaction with ChaSerg.
Disclose in
         which capacity Mr. Benhamou was acting in arranging this introductory
meeting and why
         he initiated contact.
16.      Disclose the extent to which Mr. Benhamou was involved in the
discussions and
         negotiations of the merger for each party.
17.      Expand your discussion of the parties' negotiation of material aspects
of the proposed
         transaction, including the specific, material terms proposed in each
letter of intent and
         draft of the merger agreement, the terms and conditions of the final
merger agreement, the
         determination of the final structure of the proposed transaction, and
the ultimate amount
         and form of consideration.
18.      Please include in the timeline the May 2019 purchase by BGV, Mr.
Benhamou's affiliate,
         of $15 million common and preferred shares of Grid Dynamics.
Proposal No. 1: The Business Combination Proposal
Opinion of ChaSerg's Financial Advisor, page 85

19.      Please disclose the enterprise value of Grid Dynamics implied by the
merger
         consideration when comparing the results of each analysis.
Board of Directors' Reasons for the Approval of the Business Combination, page
92

20.      Please discuss the board's consideration of the affiliated nature of
the business
         combination, including the $15 million investment in Grid Dynamics by
BGV, Mr.
         Benhamou's affiliate, during the negotiations.
Unaudited Financial Projections of Grid Dynamics, page 94

21.      You generally refer to assumptions on which the projected financial
information of Grid
         Dynamics is based. Please disclose the basis for and material
assumptions underlying the
         projections, including the main growth assumptions underlying the
projections.
 Lloyd Carney
ChaSerg Technology Acquisition Corp
December 23, 2019
Page 5
Proposal No. 5: The Incentive Plan Proposal
Number of Awards Granted to Employees, Consultants, and Directors, page 112

22.      You disclose that ChaSerg and Grid Dynamics have agreed to a future
schedule of awards
         to be made under the 2020 Plan, subject to the approval of the
Successor's board of
         directors or its compensation committee, and you provide tables
outlining the anticipated
         amount of initial awards and future awards that will be received by
certain employees
         under the schedule. To the extent practicable, please disclose such
information in
         accordance with the tabular format specified in, and the instructions
provided by, Item 10
         of Schedule 14A.
Grid Dynamics Management's Discussion and Analysis of Financial Condition and
Results of
Operations
Overview, page 146

23.      When presenting non-GAAP financial measures, please ensure that such
disclosure is
         accompanied by the corresponding GAAP measure with equal or greater
prominence. For
         example, on page 147 you refer to improving Adjusted EBITDA
performance, but do not
         include a similar discussion referring to the impact of the
corresponding GAAP measure.
         In addition, you present adjusted pro form diluted EPS without
presenting GAAP EPS.
         Please revise. Refer to Question 102.10 of the Non-GAAP Compliance and
Disclosure
         Interpretations.
Customer Concentration, page 149

24.      You state that Grid Dynamics' ability to retain and expand its
relationships with existing
         customers is one of the key indicators of its revenue potential. As
such, please include a
         quantified discussion of your net revenue retention rate for each
period presented as
         provided in the DEF14A filed on December 4, 2019. Also, ensure that
you disclose how
         this measure is determined and address any material fluctuations in
such rates.
Key Performance Indicators and Other Factors Affecting Performance
Attrition, page 149

25.    We note that Grid Dynamics' management targets a voluntary attrition
rate in managing
       the business and attrition is one of the key factors affecting
performance. Please disclose
       the voluntary attrition rate for each period presented. In addition,
disclose the employee
FirstName LastNameLloyd Carney
       utilization measures that management views as key indicators of
performance. Refer to
Comapany NameChaSerg Technology Acquisition Corp and Section III.B.1 of SEC
Release
       Instruction 1 to paragraph 303(a) of Regulation S-K
       33-8350.
December 23, 2019 Page 5
FirstName LastName
 Lloyd Carney
FirstName LastNameLloyd Carney
ChaSerg Technology Acquisition Corp
Comapany23, 2019
December NameChaSerg Technology Acquisition Corp
Page 6
December 23, 2019 Page 6
FirstName LastName
Results of Operations, page 153

26.      You state that Grid Dynamics' profit margins are subject to volatility
between periods due
         to changes in foreign exchange rates relative to the US dollar. We
note that a significant
         percentage of Grid Dynamics' combined cost of revenue and operating
expenses are
         denominated in the Russian ruble, Ukranian hryvnia and Polish zloty.
To the extent
         material and determinable, please describe and quantify the impact
that exchange rate
         fluctuations had on your cost of revenue and operating expenses. Refer
to FRC 501.09(b).
Description of Successor Securities, page 191

27.      You disclose on pages 5 and 105 that your bylaws following the
Business Combination
         will include an exclusive forum provision that is similar to the
provision that your existing
         certificate of incorporation contains. Please briefly describe the
nature and effect of
         this provision. Further, disclose whether the provision also applies
to claims under the
         Securities Act or the Exchange Act. In that regard, we note that
Section 27 of the
         Exchange Act creates exclusive federal jurisdiction over all suits
brought to enforce any
         duty or liability created by the Exchange Act or the rules and
regulations thereunder, and
         Section 22 of the Securities Act creates concurrent jurisdiction for
federal and state courts
         over all suits brought to enforce any duty or liability created by the
Securities Act or the
         rules and regulations thereunder. If the provision will apply to
claims under the federal
         securities laws, state that there is uncertainty as to whether a court
would enforce such
         provision and that investors cannot waive compliance with the federal
securities laws and
         the rules and regulations thereunder, and provide a risk factor. If
the provision will not
         apply to actions arising under the Securities Act or Exchange Act,
please also ensure that
         the exclusive forum provision in the bylaws states this clearly, or
tell us how you will
         inform investors in future filings that the provision does not apply
to any actions arising
         under the Securities Act or Exchange Act.
28.      We note that your amended and restated certificate of incorporation
will specifically deny
         the ability of stockholders to call a special meeting; require advance
notice of stockholder
         nominations for the election of directors and of business to be
brought by stockholders
         before any meeting of the stockholders; and provide that any action
required or permitted
         to be taken by the stockholders may not be effected by written consent
of the
         stockholders. Please highlight these provisions in this section of the
proxy statement.
Grid Dynamics Notes to Consolidated Financial Statements
Note 3 - Restatement, page F-57

29.      Please explain further to us the nature of the error that resulted in
the incremental stock-
         based compensation expense adjustment in fiscal 2018 and why a similar
correction was
         not needed for fiscal 2017. Also, clarify whether adjustments were
also made to the fiscal
         2017 financial statements to reclassify retention bonuses and
depreciation expense and if
         not, explain why.
 Lloyd Carney
ChaSerg Technology Acquisition Corp
December 23, 2019
Page 7
General

30.      In your response letter, please provide your analysis of why the
proposed issuance of
         common stock of ChaSerg pursuant to the business combination
transaction does not
         require registration under the Securities Act of 1933.
        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.

        You may contact Joyce Sweeney, Staff Accountant, at (202) 551-3449 or
Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Bernard Nolan,
Staff Attorney, at
(202) 551-6515 or Kathleen Krebs, Special Counsel, at (202) 551-3350 with any
other questions.



FirstName LastNameLloyd Carney                                Sincerely,
Comapany NameChaSerg Technology Acquisition Corp
                                                              Division of
Corporation Finance
December 23, 2019 Page 7                                      Office of
Technology
FirstName LastName
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