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CORRESP
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    Unassociated Document

    December
15, 2009

    Securities
and Exchange Commission

    100 F
Street, N.E.

    Washington,
D.C. 20549

                Re:

                Willamette Valley Vineyards,
      Inc.

                Form
      10-K for Fiscal Year Ended December 31,
2008

                File
      No. 0-21522

                Filed
      on March 31, 2009

    Ladies
and Gentlemen:

    We have received your letter dated
December 2, 2009, in which you had two comments to the Form 10-K for Fiscal Year
Ended December 31, 2008 (the “2008 Form 10-K”) previously filed by Willamette
Valley Vineyards, Inc. (the “Company”) with the Securities and Exchange
Commission (the “Commission”) on March 31, 2009. The Company’s responses to the
Commission’s comments are set forth below. In addition, an amendment to the 2008
Form 10-K (the “Amendment”) containing changes incorporating certain of the
Company’s responses to the Commission’s comments is filed with this
letter.

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

    1.           Commission’s
Comment:  We note from your response to comment 2 of our letter
dated November 5, 2009, you do not believe that the material weakness related to
the lack of adequate job sufficient accounting and finance personnel has had a
pervasive effect upon your financial reporting due to your ability to make the
necessary reconciling adjustments to your financial
statements.  Please tell us whether the necessary reconciling
adjustments are identified by management or by your auditors.  To the
extent they are identified by your auditors, explain to us why you believe that
the impacts of inadequate accounting and finance personnel are limited to those
areas where significant audit adjustments arose and do not affect all areas of
financial reporting.

    Company
Response:  The
Company has amended its 2008 Form 10-K to provide disclosures responsive to the
Commission’s comments. The reconciling adjustments posted to our 2008
closing trial balance were identified by both the company’s internal accounting
personnel and our auditors after our closing trial balance was provided to our
auditors for their final fieldwork in February. Of the adjustments posted during
this period, one was deemed to be a significant fourth quarter adjustment and
was disclosed in Footnote 14 of our 2008 financial
statements.   This adjustment, which increased cost of goods sold
and decreased ending inventory by $140,540 for the allocation of certain
produced wine expenditures to the cost of goods sold, was identified by our
auditors.  The other significant fourth quarter adjustment disclosed
in Note 14 of our 2008 financial statements for the adjustment of inventory for
our year-end physical count was identified by management prior the time our
closing trial balance was provided to our auditors.   There were
other insignificant adjustments identified by both management and our auditor
after the commencement of the audit final fieldwork.

    Given the
reconciling adjustments posted during the year-end financial statement close,
combined with the year-end physical inventory adjustment, we undertook an
evaluation of the underlying causes of these errors, including an evaluation the
accounting and finance personnel, in connection with our assessment of the
effectiveness of internal control over financial reporting at December 31,
2008.   We expanded the scope of the related reconciliations and
as well as additional analysis of other accounts in light of the material
weaknesses identified.  We believe the additional procedures performed
by management subsequent to the commencement of our auditors fieldwork, but
prior to the filing of our Form 10-K mitigated the risk of material misstatement
in the financial statements.

    Item 10. Directors,
Executive Officers and Corporate Governance, page 44

    1.           Commission’s
Comment:  We note that you disclose various positions held by
Mr. Fox, but you do not state the years in which he occupied such positions or
the principal business of the identified company.  Please revise to
provide this information.  See Item 401(e)(1) of Regulation
S-K.

    Company
Response:  In
response to the Commission’s comment, the Company has amended its 2008 Form 10-K
to provide disclosures under Item 401 of Regulation S-K with respect to Mr. Fox
pursuant to Item 10 of Part III of Form 10-K. We refer the Commission to the
Amendment filed with this letter.

    We hope
that the foregoing responds to the Commission’s comments to its
satisfaction.

    In
connection with the Company’s response to the Commission’s comments, the
undersigned hereby acknowledges on behalf of the Company 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 by the Commission or any person under the federal securities
      laws of the United States.

    If you
have any questions regarding the foregoing please contact the undersigned at
(503) 588-9463.

              Sincerely,

              /s/
      James W. Bernau

              James
      W. Bernau

              President
      and Chief Executive Officer, Willamette Valley Vineyards,
    Inc.