April 13, 2020

George Syllantavos
Co-Chief Executive Officer, Chief Financial Officer, and Director
Growth Capital Acquisition Corp.
The Chrysler Building
405 Lexington Avenue
New York, NY 10174

       Re: Growth Capital Acquisition Corp.
           Amendment 1 to Draft Registration Statement on Form S-1
           Submitted April 3, 2020
           CIK 0001498233

Dear Mr. Syllantavos:

       We have reviewed your amended draft registration statement and have the
following
comment. In our comment we may ask you to provide us information so that we may
better
understand your disclosure.

        Please respond to this letter by providing the requested information
and either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe that our comment applies to your facts and
circumstances or do
not believe that an amendment is appropriate, please tell us why in your
response.

      After reviewing the information you provide in response to the comment
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment 1 to Draft Registration Statement on Form S-1 submitted April 3, 2020

Change In Auditor, page 153

1.     We have reviewed your response to prior comment 4. Item 304(a)(1)(ii) of
Regulation S-
       K requires a statement whether the accountant's report on the financial
statements for
       either of the past two years contained an adverse opinion or a
disclaimer of opinion or was
       qualified or modified as to uncertainty, audit scope, or accounting
principles and a
       description of the nature of each such adverse opinion, disclaimer of
opinion,
       modification, or qualification. This would include disclosure of
uncertainty regarding the
       ability to continue as a going concern in the accountant's report. As
such, please revise
       your disclosure. Please also provide an updated exhibit.
 George Syllantavos
Growth Capital Acquisition Corp.
April 13, 2020
Page 2

        You may contact Jeffrey R. Gordon, Staff Accountant, at (202) 551-3866
or Anne M.
McConnell, Staff Accountant, at (202) 551-3709 if you have questions regarding
comments on
the financial statements and related matters. Please contact Edward M. Kelly,
Senior Counsel, at
(202) 551-3728 or Asia Timmons-Pierce, Special Counsel, at (202) 551-3754 with
any other
questions.



                                                           Sincerely,
FirstName LastNameGeorge Syllantavos
                                                           Division of
Corporation Finance
Comapany NameGrowth Capital Acquisition Corp.
                                                           Office of
Manufacturing
April 13, 2020 Page 2
cc:       Jeffrey W. Rubin, Esq.
FirstName LastName