SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-3561

      MAIL STOP 3561
 November 5, 2009
 Mr. James W. Bernau, President Willamette Valley Vineyards, Inc. 8800 Enchanted Way, S.E. Turner, Oregon 97392
 Re: Willamette Valley Vineyards, Inc.
Form 10-K for Fiscal Year Ended December 31, 2008  File No. 0-21522
  Filed on March 31, 2009

Dear Mr. Bernau:
We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some comments, we have asked you to provide us with additional information so we may
better understand your disclosure.  Please do so within the time fram e set forth below.
You should comply with the remaining comment s in all future filings, as applicable.
Please confirm in writing that you will do so and also explain to us how you intend to
comply, within the time frame set forth below.   Please understand that after our review of
all of your responses, 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 comment or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter

Mr. James W. Bernau
Willamette Valley Vineyards, Inc.
November 5, 2009 Page 2   Controls and Procedures, page 41

 Evaluation of Disclosure Cont rols and Procedures, page 41

1. Please expand your discussion of disclosure  controls and pro cedures to explain
the basis for your “ineffective” conclusion.  Identify and describe in sufficient
detail any material weaknesses or deficien cies that led to th e present conclusion,
when the weaknesses were discovered and by whom.  Disclose management’s plans to remediate these weaknesses.

Management’s Report on Internal Control over Financial Reporting, page 42

2. Revise the discussion of internal controls  over financial report ing to clarify when
each of the material weaknesses was identi fied and by whom, as well as when the
material weakness first began.  Discu ss how you were able to present GAAP-
compliant financial statements in the Form 10- K.  It appears to us  that the lack of
sufficient qualified personnel and lack of  appropriate procedures and controls
have had a pervasive effect upon Willamette’s financial reporting and the overall control environment.  Please clarify your disc losure if that is th e case or explain to
us why you believe the weaknesses have  not had a pervasive effect.
 Executive Compensation, page 46

3. We note that Mr. Fox has signed the Fo rm 10-K as the CFO/Controller and
Principal Accounting Officer.  Please e xplain why he is not included in the
disclosure regarding officers and director s set forth in Item 401 of Regulation S-
K.
 Closing comments

  As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ent to expedite our review.  Please furnish
a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.
 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under

Mr. James W. Bernau
Willamette Valley Vineyards, Inc. November 5, 2009 Page 3  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 comment, please provide, in writing, a statement from the company acknowledging that:
• 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.     Any questions may be directed to Ca they Baker at (202) 551-3326 or to Pam
Howell at (202) 552-3357, who superv ised the review of your filing.

        S i n c e r e l y ,
           John Reynolds         A s s i s t a n t  D i r e c t o r    cc: Willamette Valley Vineyards, Inc.  FAX:  (503) 362-0062