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SEC Comment Letter for WILLAMETTE VALLEY VINEYARDS INC (WVVI, WVVIP) (CIK 0000838875) (WVVI) — Feb 1, 2016

WILLAMETTE VALLEY VINEYARDS INC (WVVI, WVVIP) (CIK 0000838875)
Date: Feb. 1, 2016 · CIK: 0000838875 · Accession: 0000000000-16-063208

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 001-37610

Date
January 29, 2016
Author
/s/ James Lopez (for)
Form
UPLOAD
Company
WILLAMETTE VALLEY VINEYARDS INC (WVVI, WVVIP) (CIK 0000838875)

Letter

Mail Stop 3561 January 29, 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 Response Dated January 15, 2016 File No. 001-37610

Dear Mr. Bernau :

We have reviewed your January 15, 2016 response to our comment letter and have the following comment s. In some of our comments , we may ask you to provide us with information so we may better 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. Unless we note otherwise, our references to prior comments are to com ments in our January 8, 2016 letter .

General

1. We note your response to comment 2 and we reissue the comment. If you wish to obtain authority to adjourn the meeting to solicit additional proxies, please revise your proxy card and disclosure to clearly reflect such purpose.

James W. Bernau Willamette Valley Vineyards, Inc. January 29, 2016 Page 2

Please contact Hillary Daniels at (202) 551 -3959 or James Lopez at (2 02) 551 -3536 with any questions .

Sincerely,
/s/ James Lopez (for)

Show Raw Text
Mail Stop 3561

January 29, 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
 Response Dated January 15, 2016
File No. 001-37610

Dear Mr. Bernau :

We have reviewed  your January 15, 2016  response to our comment  letter  and have the
following comment s.  In some of our comments , we may ask you to provide us with information
so we may better 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.
Unless we note otherwise, our references to prior comments are to com ments in our January 8,
2016  letter .

General

1. We note your response to comment 2 and we reissue the comment.  If you wish to obtain
authority to adjourn the meeting to solicit additional proxies, please revise your proxy
card and disclosure to clearly reflect such purpose.

James W. Bernau
Willamette Valley Vineyards, Inc.
January 29, 2016
Page 2

 Please contact Hillary Daniels at (202) 551 -3959 or James Lopez at (2 02) 551 -3536 with
any questions .

Sincerely,

 /s/ James Lopez (for)

John Reynolds
Assistant Director
Office of Beverages, Apparel, and
Mining

cc: Marcus Williams, Esq.
Davis Wright Tremaine LLP