SecProbe.io

Mail Stop 3561

January 8, 2016

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.
 Form PRE 14A
Filed December 24, 2015
File No. 001-37610

Dear Mr. Bernau :

We have limited our review of your filing 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 be tter understand your disclosure .

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

General

1. We note that you are asking shareholders to approve an increase i n the number of
authorized Series A Redeemable Preferred Stock.  Please tell us what consideration you
gave to providing financial information pursuant to Item 11(e) and Item 13 of Schedule
14A.  Refer to Instruction 1 to Item 13 .

2. It appears that you seek  discretionary authority to adjourn the meeting for the purpose of
soliciting additional proxies.  Please note that the staff does not view such postponement
or adjournment as a matter “incident to the conduct of the meetings,” as described in Rule
14a-4(c)(7).  If you wish to obtain authority to adjourn the meeting to solicit additional
proxies, please revise your proxy card and disclosure accordingly.

James W. Bernau
Willamette Valley Vineyards, Inc.
January 8, 2016
Page 2

 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 the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are respon sible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written 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 comments as a defense in any proceeding initiated b y
the Commission or any person under the federal securities laws of the United States.

Please contact Hillary Daniels  at (202) 551 -3959  or James Lopez  at (202) 551 -3536  with
any questions.

Sincerely,

 /s/ James Lopez (for)

John Reynolds
Assistant Director
Office of Beve rages, Apparel, and
Mining

cc: Marcus Williams, Esq.
Davis Wright Tremaine LLP