SecProbe.io

September 27, 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 amended registra tion statement and have the following
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 further amendment to your registration statement and the
information you provide in response to these co mments, we may have additional comments.

Form S-1/A, filed September 13, 2010

Summary
 1. Please reconcile the disclosure that you plan to offer 2 varietals during the next 12 months with the disclosure that you hope to begin sales nine months following the
placement of the offering.  We note that the o ffering will last for up to six months.  In
addition, we partially reissue comment th ree of our letter da ted August 4, 2010.  We
continue to note the reference in the summary  to beginning sales nine months following
the placement of the offering.  Please clarify whether this re fers to the commencement of
the offering or the completion of the offeri ng.  Such disclosure was not revised as
indicated in your supplemental response.

Michael Moore Superior Venture Corporation
September 27, 2010 Page 2

2. We reissue comment four of our letter dated August 4, 2010.  We continue to note statements that appear to be promotional in  nature.  Please remove  such disclosure or
provide the basis for the statements.  For instance, please provide the basis for your
estimate in the first risk factor that by the third quarter of operations “revenue will support the expense [of hiring additional employees].”

Risk Factors

3. We reissue comment five of our letter  dated August 4, 2010.  Please add a separate  risk
factor discussing the going concern raised by the independent public accountant.
 Use of Proceeds, page 13

 4. We reissue comment seven of our letter da ted August 4, 2010. Please discuss in greater
detail what you mean by “changing needs of the business” and “m arket opportunities.”
Again, the company may reserve the right to change the use of proceeds, provided such
reservation is due to certain contingencies that are discusse d specifically.  See Instruction
7 to Item 504 of Regulation S-K and revise your disclosure accord ingly.  Please revise
similar disclosure in the Pl an of Operations section.

Description of Our Business, page 19

5. We reissue comment nine of our letter dated August 4, 2010.  Please reconcile the
disclosure in the summary and in the busine ss overview that your business plan is to
“produce” and sell wine varietals with the disclosure on page 19 where you refer to
growers and wineries that you have iden tified that you hope will produce your wine.

6. We note your revised disclosure in response to  comment ten of our letter dated August 4,
2010 and we partially reissue the comment.  Pl ease provide a more detailed discussion of
your proposed products.  Please further discu ss in greater detail your proposed methods
of distribution.  For instance, it is unclea r how the president will pursue word-of-mouth,
small local distributors, and developed business relationships in the Denver and
surrounding areas.

Michael Moore Superior Venture Corporation
September 27, 2010 Page 3

Industry Analysis, page 20

 7. We note your revised disclosure in response to comment 11 of our letter dated August 4,
2010.  Please revise the citation you provide here and where a ppropriate, as there appears
to be a typographical error.  We are unable to locate the website page listed.   Please
further revise to clarify wh ether the citations you provi de pertain to all industry
statements included.  If they do not, please provi de the source(s) of such information.  As
a non-exclusive example, we note the statem ent that wine consumption rose 3.8% to
268.1 million 9-liter cases in the early and mid 2000’s.  This would also include
statistical information found thr oughout the business section.  In addition, please cite to
the specific reports from the www.strategyr.com
 website to which you have cited
information.  Lastly, please provide us supplementally with  a copy of each source of
information cited throughout the pros pectus, as previously requested.
 Marketing, page 21

 8. We note your revised disclosure in response to comment 12 of our letter dated August 4,
2010.  Please revise to clarify whether the cita tion you provide pertains  to all statistical
and factual information included in your Target  Market Segmentation section.  If this is
not the case, please provide the source(s) for such statements.  As a non-exclusive
example, we note the statement, “[t]he third sp ecific target market of Superior Venture is
women, because they have historically purchas ed 64% of all table wines.” (emphasis
added)  Furthermore, please revise your cita tion to more clearly disclose where to find
the information.  In this regard, we note that  the website provided takes the reader to an
archive page rather than an article.
 9. We partially reissue comment 13 of our le tter dated August 4, 2010.  However, we note
that references to “a variety of  target market specific marke ting strategies” have not been
removed from your prospectus.  Please discuss in greater detail th is strategy, including
how your marketing strategy is different from the competition, or remove these
statements as they would appear promotional in nature.

Sales Strategy, page 22

10. We reissue comment 16 of our letter dated August 4, 2010.  Please be more specific with
respect to how much time Mr. Moore expects to spend running the company’s marketing
campaign.  In addition, revise your prospectus to incorporate this response.

Financial Statements, page 27

11. Please note the updating requirements for your financial statements as set forth in Rule 8-
08 of Regulation S-X.

Michael Moore Superior Venture Corporation September 27, 2010 Page 4

Directors, Executive Officers, Promoters and Control Persons, page 40

 12. We partially reissue comment 23 of our le tter dated August 4, 2010.  Please revise your
disclosure to incorporate your  supplemental response addressing the specific experience,
qualifications, attributes, or skills that led to the conclusion that Mr. Moore should serve
as a director of the company.  See Item 401(e)(1) of Regulation S-K.

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.
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