SecProbe.io

Mail Stop 3561
        December 1, 2006
Mr. James W. Bernau
President
Willamette Valley Vineyards, Inc.
8800 Enchanted Way, SE
Turner, OR  97392

Re: Willamette Valley Vineyards, Inc.
  Form 10-KSB for the Fiscal Year Ended December 31, 2005
  Filed March 31, 2006
  Form 10-Q for the Quarterly Period Ended September 30, 2006
  Filed November 14, 2006
  File No. 0-21522

Dear Mr. Bernau:

We have reviewed your filings and have the following comments.  We have
limited our review to your fi nancial statements and relate d disclosures and do not intend
to expand our review to other portions of  your document.  Please provide a written
response to our comments.  Please be as deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-KSB for the Fiscal Year Ended December 31, 2005

Description of Business

Vineyard

1. We note that you entered into a long-term grape purchase agreement with a grower from whom you must purchase their yield at fixed contract prices through
2015.  Please revise future filings to di sclose the significant terms of the long-

Mr. James W. Bernau
Willamette Valley Vineyards, Inc.
December 1, 2006 Page 2
term grape purchase agreement in the f ootnotes to your financial statements.
Please also disclose the future mini mum payments under the agreement, as
applicable.  In responding to our comment , please provide us with all pertinent
terms of the agreement, including the quant ities to be purchase d, repercussions for
non-performance, and any provisions that  convey the right to use of the
underlying property.

Notes to Financial Statements

1.  Summary of Operations, Basis of Pres entation and Significant Accounting Policies

Cost of Goods Sold

2. Please tell us how you allocate admini strative support, purchasing, receiving,
warehousing, and other fixed overhead costs to  inventory units.  Please also tell us
the percentage of the total cost that  these various fixed costs represent.

11. Commitments and Contingencies

3. We note that you deferred only a portion of  the total gain on your December 2005
sale-leaseback transaction.  Since it a ppears you recognized the remaining gain in
income on the date of sale, please tell us and clarify your disclosures in future
filings to clearly indicate why you did not defer the entire gain on sale.

Controls and Procedures

4. We note your disclosure that your Chief Executive Officer and Chief Financial Officer concluded that your disclosure c ontrols and procedures were effective to
ensure that information required to be  disclosed in your filing is recorded,
processed, summarized, and reported within  the time periods specified in the
SEC’s rules and forms.  Please confirm to us , if true, and revise your disclosure in
future filings to indicate that your officer s concluded that your disclosure controls
and procedures were also effective to ensure that information required to be
disclosed in the reports that you file  or submit under the Exchange Act is
accumulated and communicated to management, including, your principal executive and financial officers, to a llow timely decisions regarding required
disclosure.  Refer to Exchange Act Rule 13a-15(e).

5. We note that you designed your disclosure controls and procedures to provide
“reasonable assurance” of achieving the desired control objectives.  In future filings, please revise your conc lusion that your disclosure controls and procedures
were effective to reflect, if true, that th e disclosure controls and procedures were
effective at the “reasonable assurance” level.  Please re fer to Part II.F.4 of SEC
Release No. 33-8238 for guidance.  Please note your statement that a control

Mr. James W. Bernau
Willamette Valley Vineyards, Inc.
December 1, 2006 Page 3
procedure “can provide only reasonable , not absolute, assurance that the
objectives of the control procedure are me t” is not sufficient in this regard.

Form 10-QSB for the Quarter Ended September 30, 2006

Notes to Unaudited Interim Financial Statements

2)  Stock Based Compensation

6. We note that you adopted SFAS No. 123(R) effective January 1, 2006.  Please revise future filings to disclose the eff ect of the change on income before income
taxes, net income, cash flow from
operations, cash flow fr om financing activities
and basic and diluted earnings per share.   Please also disclose the methodology
you used to transition to accounting for st ock-based compensation using the fair
value method.  For awards modified in  anticipation of adopting SFAS 123(R),
please tell us and disclose the reasons fo r modifying the terms of the applicable
awards.  Refer to paragraphs 74-78 a nd 84 of SFAS No. 123(R) and SAB Topic
14-K.

7. Please reconcile for us the difference between the product of the shares and
weighted average exercise price of options exercised during the nine months
ended September 30, 2006 and the amount you present as proceeds from stock
options exercised in the cash flows from  financing activitie s section of your
statement of cash flows for the same period.

* * * * *

 Please respond to these comments within 10 business days or tell us when you
will provide us with a response.  Please furnish a cover letter that keys your responses to
our comments and provides any requested in formation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your responses to our comments.

  We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:

Mr. James W. Bernau
Willamette Valley Vineyards, Inc.
December 1, 2006 Page 4
‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;

‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

‚ the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

 You may contact Scott R uggiero at (202) 551-3331 or Andrew Blume at (202)
551-3254 if you have questions regarding comm ents on the financial statements and
related matters.  Please contact me at  (202) 551-3716 with any other questions.

Sincerely,

William Choi
Branch Chief