United States securities and exchange commission logo June 4, 2020 Daniel E. Bachus Chief Financial Officer Grand Canyon Education, Inc. 2600 W. Camelback Road Phoenix, Arizona 85017 Re: Grand Canyon Education, Inc. Form 10-K for the Fiscal Year Ended December 31, 2019 Filed February 20, 2020 Form 10-Q for the Interim Period Ended March 31, 2020 Filed May 7, 2020 File No. 001-34211 Dear Mr. Bachus: We have completed our review of your filings. 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. Sincerely, Division of Corporation Finance Office of Trade & Services