SecProbe.io

August 4, 2010

Michael Moore, President, CEO, Director Superior Venture Corporation 1937 E. Mineral Avenue Centennial, Colorado 80122

Re: Superior Venture Corporation
Registration Statement on Form S-1
Filed July 16, 2010
  File No. 333-168136

Dear Mr. Moore:

We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de 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 re gistration statement and the information you
provide in response to these comments, we may have additional comments.
 Form S-1, filed July 16, 2010

 Prospectus Summary, page 5

 1. Please provide the registrant’s telephone num ber, in addition to its complete mailing
address, of its principle execu tive offices.  Please refer to Item 503(b) of Regulation S-K.

2. We note the statement that you have “not  significantly commenced [your] planned
principal operations.”  Please explain, as it appears that you have not commenced your
planned principal operations.  Revise similar disclosure  throughout the prospectus.

3. Please clarify the statement th at you anticipate sales to begi n approximately six months
following the placement of your offering.  Do you mean the commencement or completion of your offering?  In addition, your milestones section states you will not receive the shipment of the first cases of production run until approxi mately months 7-9.
Please reconcile and revise.

Michael Moore Superior Venture Corporation
August 4, 2010 Page 2

4. Please remove the statements that are promotional in nature, such  as “continuing these
innovative efforts will lead to a fair return  on investment to our stockholders” and “we
believe that recurring revenues from our products will be sufficient to support ongoing
operations,” as such statements appear promo tional in light of the development stage of
the company.  Revise throughout the prospectus to remove promotional statements.
 Risk Factors, page 8

 5. Please add a risk factor disc ussing the going concern raised  by the independent public
accountant.
 Use of Proceeds, page 13

 6. We note that the company intends to use a por tion of the proceeds from this offering to
pay “Salaries/Contractors.”  To  the extent that the proceeds may be used to pay the CEO,
please provide disclosure pursuant to Item 504 of Regulation S-K.  To the extent the
company will not be using any proceeds to pay the CEO, please disclose.
7. We note the disclosure that  “any line item amounts not expended completely shall be
held in reserve as working capital and s ubject to reallocation to other line item
expenditures as required for ongoing operations.”   The company may reserve the right to
change the use of proceeds, provided that such  reservation is due to certain contingencies
that are discussed specifically and the alternatives to such us e in that event are indicated.
See Instruction 7 to Item 504 of Regulati on S-K.  Please revise the disclosure
accordingly.
 Common Stock, page 17

 8. The statement that “all shares of common st ock now outstanding are fully paid for and
non-assessable” is a legal conclusion that you are unable to make.  Please revise to
attribute this statement to counsel or remove.
 Description of our Business, page 18

 9. Please reconcile the disclosure in the summa ry and in the business overview that your
business plan is to produce and sell wine varietals with the disclosure on page 19, where you refer to growers and wine ries that you have identifie d to produce your wine.  In
addition, please disclose whet her you have had any discussi ons or negotiations with any
growers or wineries.  If you ha ve any agreements, please file as exhibits and discuss the
material terms.  To the extent that y ou have no agreements and/or have had no
discussions with growers and wineries, clearly disclose.

Michael Moore Superior Venture Corporation
August 4, 2010 Page 3

10. Please provide a more detailed discussion of your proposed products and the markets,
such as where you plan to initially sell your products.  See Item 101(h)(4)(i) of
Regulation S-K.  In addition, provide a more detailed discussion of your proposed distribution methods for your proposed products.  See Item 101(h)(4)(i i) of Regulation S-
K.
 Industry Analysis, page 19

 11. We note the disclosure in this section and elsewhere in the business section, where you
provide industry information.  Please provide the source(s)  of such information.  In
addition, please provide the citation for wh ere investors can find the information and
provide us supplementally with a copy of the information cited.
 Marketing, page 19

Target Market Segmentation, page 20
 12. Please provide the basis for statements made in this section.  For instance, we note the
reference to adults aged 50 and up as having “the largest increase and they are the most
frequent wine drinker” and the statement that  “statistics reveal that [children of the 50
and over segment] are adopting wine  as their parents did . . .”

13. You discuss throughout the prospectus that  you plan to differentiate yourself by “a
variety of target market specific marketing strategies” and by init iating “an aggressive
high-voltage and innovative sales and marketing strategy.”  Please discuss this strategy in
greater detail, including how your  marketing strategy is different from the competition, or
remove these statements as they would appear promotional in nature.
 14. Please explain the statement that “management is well seasoned on marketing to various business segments.”  It appears that your sole officer and director has been a manager and wine buyer for restaurants.
 Promotional Strategy, page 20

 15. We note that points of promotion include “[c]elebrities being seen with our products,” “[a]ppearances on television shows and specifi cally reality TV shows,” and “[f]eature
films.”  Please revise to disclose your basis fo r these statements especially in light of the
fact that you are only rais ing $50,000 in this offering.
 Sales Strategy, page 21

 16. Please describe in more detail how you will r un the marketing campaign.  In this regard,
we note that you are only able to devote 10 hours of time per week to the company.

Michael Moore Superior Venture Corporation
August 4, 2010 Page 4

Competitor Analysis, page 21

 17. We note your statement that “industry reports su ggest that in the coming years wine is set
to make gains . . .” Please revise to disclose  to what industry reports you are specifically
referring.
18. Please provide a more detailed discussion of  the competitive business conditions and the
company’s competitive position in the industr y and methods of competition.  See Item
101(h)(4)(iv) of Regulation S-K.
12 Month Growth Strategy and Milestones, page 21

 19. We note your quarterly schedule of milest ones on page 22 and your more specific
disclosure on page 36.  We further note that you are a development stage company
without revenue.  Please disclose how the co mpany plans to achieve revenue generation.
For instance, please discuss, am ong other things, to what exte nt the company must secure
additional funding in order to meet the m ilestone schedule and budgeted costs, what
funding will be sought, and how the company will proceed if the company is unable to
obtain such funding.

Government and Industry Regulation, page 23

20. We note that your business will be subject to federal laws and regulations and to business
and tax rules and regulations.  Please revise to disclose thos e laws, regulations, and rules
that pertain to your business and what impact each has on it.

Financial Statements, page 26
 21. Please note the updating requirements for your financial statements as set forth in Rule 8-08 of Regulation S-X, and provide a currently dated consent from your independent accountant with all amendments.
 Management’s Discussion and Analysis, page 35

 22. Please revise to disclose the company’s cash balance as of the most recent practicable date.

Michael Moore Superior Venture Corporation
August 4, 2010 Page 5

Directors, Executive Officers, Promoters and Control Persons, page 38

 23. Please provide the business experience for Mr. Moore for the past  five years.  In addition,
for each employment discussed, please specific ally disclose the employment location,
titles and beginning and ending dates of employment.  Also, please clarify whether Seven
30 South is a restaurant.  Refer to Item 401(e)(1) of Regulation S-K as appropriate.
Lastly, please briefly discuss the specific expe rience, qualifications, at tributes or skills
that led to the conclusion that the sole director should serve as a director of the company.
See Item 401(e)(1) of Regulation S-K.
 Executive Compensation, page 39

 24. It appears that you are using an outdated summary compensation table.  Please revise to
provide the current table.  Refer to Item 402( n) of Regulation S-K for further information.
 Compensation of Directors, page 39

 25. We note that directors are permitted to receive fixed fees and other compensation for their services as directors.  We also note your statement th at “[d]irectors are entitled to
reimbursement for expenses in attending meetings but receive not other compensation for
services as directors.”  Please reconcile thes e two statements and re vise to clarify what
fees directors may be entitled to and for what services.

Undertakings, page 45

 26. When you determine that a particular undertak ing applies to your offering, please include
the undertaking in its entirety in the prospectus.  In this regard, we note that your undertaking, set forth in paragr aph (1)(ii), does not include th e entire language required
by Item 512(a) of Regulation S-K.
27. We note your undertaking beginning, “[p]rovide d, however, that paragraphs (1)(i) and
(1)(ii) shall not apply. . .”  Please discuss why this undert aking applies to your offering,
as this undertaking appears to relate to  offerings pursuant to S-3, or remove.
 Exhibits

 28. Exhibit 3.1 lists Jerald Bacal as the only dir ector of the company.  Please reconcile with
previous disclosure that Michael Moore is  the company’s only di rector or advise.

29. We note the disclosure in the legality opinion th at Mr. Hunt is licensed in Florida.  Please
remove this statement, as it appears to  place a limitation on the opinion, since the
company is incorporated in Nevada.

Michael Moore Superior Venture Corporation
August 4, 2010 Page 6

30. The prospectus indicates that  the subscription agreement and checks are irrevocable.  We
are unable to locate such representation in the subscription agreement.  In addition,
advise us how, under applicable state law, th e offer to subscribe to purchase shares can
legally be an irrevocable
 offer to purchase those shares or remove such disclosure.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’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 pr ovide a written statement from the company
acknowledging that:
• should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission 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 a nd 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 re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the registration statement.

Michael Moore Superior Venture Corporation August 4, 2010 Page 7

You may contact Jamie Kessel at (202) 551-3737 or Brian Bh andari at (202) 551-3390 if
you have questions regarding comments on the fina ncial statements and related matters.  Please
contact Erin Wilson at (202) 551-6047 or Pame la Howell at (202) 551-3357 with any other
questions.
Sincerely,
       John Reynolds
Assistant Director
   cc: Clifford J. Hunt, Esq.  FAX: (727) 471-0447