SecProbe.io

July 15, 2015

Via E -mail
James W. Bernau
President and Chief Executive Officer
Willamette Valley Vineyards, Inc.
8800 Enchanted Way SE
Turner, Oregon 97392

Re: Willamette Valley Vineyards, Inc.
  Registration Statement on Form S-3
Filed June 23, 2015
  File No. 333 -205174

Dear Mr. Bernau :

We have limited our review of your registration statement to those issues we have
addressed in our 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 this letter by amending your registration statement and providing the
requested information.   If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments .

General

1. Please clarify whether the company has any discretion to change the prices set forth in
the table on page 4.

2. On page 5 and elsewhere in the document you state that the Series A Redeemable
Preferred Stock will be entitled to receive dividends  at a rate equal to 5.3% per year.
However, Attachment A to Exhibit 4.1 indicates that the dividend rate is 5.0% per year.
Please reconcile.

3. Please file the escrow agreement as an exhibit.

We urge all persons who are responsible for the accuracy and ad equacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 1933 and

James W. Bernau
Willamette Valley Vineyards, Inc.
July 15, 2015
Page 2

 all applicable Securities Act rules require.   Since the company and its management are in
possession of all facts relating to a com pany’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement, please provide a wr itten statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company  may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for a cceleration.  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of  the
registration statement.

Please contact Ronald E. Alper at (202) 551 -3329 or  Pam Howell  at (202) 551 -3357  with
any questions.

Sincerely,

 /s/ Pamela Howell
 for

 John Reynolds
Assistant Director

cc: Marcus J. Williams
      Davis Wright Tremaine LLP