SecProbe.io

January 28, 2011
 Michael Moore, President, CEO, Director Superior Venture Corporation 1937 E. Mineral Avenue Centennial, Colorado 80122
Re: Superior Venture Corporation
Amendment No. 4 to Registrati on Statement on Form S-1
Filed January 14, 2011 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 amendment to your re gistration statement and the information you
provide in response to these comments, we may have additional comments.

Amendment No. 4 to Registration Statement on Form S-1

 Description of Our Business, page 19

Marketing, page 21

1. We note the disclosure in response to comme nt four of our letter dated October 27, 2010
that you have not had any discussions with specific growers or wineries.  Please add
disclosure regarding the risk that you may not  be able to find a grower or winery to
produce your wines or may not be able to ne gotiate sufficient terms of an agreement.

2. We reissue in part comment eight of our  letter dated October 27, 2010.  We note that
your target markets as discussed on page 22 under Target Market Segmentation appear to
include all demographics other than men between the ages of 33 and 44, whereas you
state in the penultimate paragraph of page  21 that your target market includes end
consumers that have disposable income and are college educated.  Furthermore, you state
in the first paragraph of page 20 that you intend to introduce a Chardonnay (due to its
general popularity) and a Merlot (due to its qualities as an “i ntroducing” wine).  In light

Michael Moore Superior Venture Corporation January 28, 2011 Page 2

 of these statements, please clarify and discu ss in greater detail your  marketing strategy
and how you intend to implement the specifi c strategy discussed.  Your disclosure
currently appears to suggest a very general target market and marketing approach, with
some focus on new wine drinkers.

3. We partially reissue comment nine of our letter dated October 27, 2010.  Please disclose
the cash balance as of the most recent practicable date.

Unaudited Interim Financial Statements

Notes to Unaudited Interim Financial Statements
General

4. Please note that interim financial statements  must include all adjustments that, in the
opinion of management, are necessary in orde r to make the financial statements not
misleading.  An affirmative statement that the financial statements have been so adjusted
must be included with the interim financia l statements.  Refer to Article 8-03 of
Regulation S-X.

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 disc losure, 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

Michael Moore Superior Venture Corporation January 28, 2011 Page 3

 public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.
 You may contact Jamie Kessel at (202) 551-3727 or Brian Bh andari, Accounting Branch
Chief, at (202) 551-3390 if you have questions regarding comments on the financial statements
and related matters.  Please contact Shehzad Ni azi at (202) 551-3121 or Pamela Howell, Special
Counsel, at (202) 551-3357 w ith any other questions.

Sincerely,
   /s/ Pamela Howell  for
John Reynolds Assistant Director