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CORRESP
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CORRESP

 May 17, 2023

 VIA
EDGAR

 Ms. Jeanne Baker

 Mr. Terrence
O’Brien

 United States Securities and Exchange Commission

Division of Corporation Finance

 Office of Industrial
Applications and Services

 100 F Street, NE

 Washington, D.C.
20549

Re:
 Village Farms International, Inc.

Form 10-K for the Year Ended December 31, 2022

Filed March 9, 2023

Item 2.02 Form 8-K filed March 9, 2023

File No. 001-38783

Dear Ms. Baker and Mr. O’Brien,

Set forth below are the responses of Village Farms International, Inc. (the “Company”) to comments received from the staff of the
Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated April 5, 2023, with respect to the Company’s Form 10-K
for the year ended December 31, 2022 (the “2022 Form 10-K”).

 For your convenience,
each response is prefaced by the exact text of the Staff’s corresponding comment. Dollar amounts presented herein are in thousands, consistent with the Company’s financial statements and periodic reports, and unless otherwise stated, are
in United States dollars (C$ = Canadian dollars).

 Form 10-K for the Year Ended
December 31, 2022

 Management’s Discussion and Analysis of Financial Condition and Results
of Operations

 Cost of Sales, page 47

1.
 Please disclose the facts and circumstances that resulted in lower potency flower inventory being
older than 12 months old causing the Company’s fourth quarter inventory write down of $11,038.

Response

The Company acknowledges the Staff’s comment and respectfully submits that the inventory write-down of $11,038 was the
result of carrying lower potency bulk flower inventory that was harvested prior to 2022 at a historical cost that was above the net realizable value at December 31, 2022. This write down is required pursuant to Accounting Standards Codification
330, Inventory (ASC 330). Historically, the Company sold its bulk flower inventory in both the retail (higher pricing) and wholesale channels (lower pricing) at an average price in excess of its historical cost. In the fourth quarter of 2022,
the Company’s older lower potency bulk flower was no longer held for sale in the retail channels, but was sold in the oversupplied and much lower priced wholesale channel at an average price below the Company’s historical cost, and the
Company continued to use this inventory for its own cannabis derivative products. As the average weighted selling price for the older lower potency bulk flower in the fourth quarter of 2022 was below the Company’s historical cost, the Company
was required to write down the value of its older lower potency bulk flower inventory, which resulted in the inventory write-down of $11,038.

This was the first inventory write-down the Company has experienced since the inception of cannabis operations and was the
result of the continued market saturation of cannabis bulk flower supply and the Company’s decision to no longer sell this older lower potency flower in retail products. See our reply to Comment #4 below for more information on inventory
adjustments versus the inventory write-down.

 The Company notes that this bulk flower is still in sellable condition
despite being harvested prior to 2022 and is being sold and continues to be sold over the course of time, and is also being used as the primary input for the Company’s cannabis derivative products. Lower potency flower was sold in the first
quarter of 2023, e.g., has been sold at pricing consistent with its net realizable value as of December 31, 2022. Accordingly, there was no further write-down recorded for this inventory in the Company’s interim financial statements for
the three months ended March 31, 2023 included in the Company’s quarterly report on Form 10-Q filed on May 10, 2023 (the “Q1 2023 Quarterly Report”).

In future filings, the Company will include appropriate and more detailed disclosure on the facts and circumstances relating to
material inventory write-downs.

 - 2 -

 Net (loss) Income Attributable to Village Farms International Inc., page
48

2.
 You recognized a $43,299 goodwill impairment charge related to your U.S. Cannabis segment in 2022.
Given your limited discussion surrounding this impairment charge, there is a concern that investors may not understand the specific facts and circumstances that led to the impairment charges. Please disclose the specific adverse business,
competitive and economic factors that led to the significant decline in this reporting unit’s fair value and provide an explanation as to why you determined that you would not be able to overcome those adverse factors. Please refer to Item
303(a)(3) of Regulation S-K and Sections 216 and 501.12.b.4 of the Financial Reporting Codification for guidance for disclosures of material impairment charges.

Response

The Company acknowledges the Staff’s comment and respectfully submits that the facts and circumstances that led to the
impairment charge were disclosed in Note 11 to the Company’s annual financial statements included in the 2022 Form 10-K. Specifically, the $43,299 of impairment charges for the U.S. Cannabis segment in
2022 related to goodwill and intangible assets from the Company’s acquisition of Balanced Health Botanicals; the Company determined that these assets were impaired as of June 30, 2022, and the goodwill assets were impaired as of
December 31, 2022. As discussed in Note 11 to the Company’s financial statements, these impairments were a direct result of ongoing regulatory challenges regarding cannabidiol (“CBD”) that have negatively impacted retail sales of
CBD products and have limited the growth opportunities for the Company’s U.S. cannabis business.

 Under the Farm Bill
of December 2018, CBD was legalized in the United States, following which there initially had been significant U.S. market interest in the sale of CBD products. This, in turn, led to significant national interest in CBD and CBD infused products. On
the back of the strong 2019 and 2020 CBD growth in demand, the Company acquired Balanced Health in August 2021 in an arm’s length transaction. The acquisition accounting allocation of the purchase price had allocated much of the value of the
acquired business to goodwill. Since then, the Food and Drug Administration (“FDA”) has increasingly signaled that it would be treating CBD to be a “medicine” and not a supplement, and as such, until further FDA approved studies
were provided and reviewed, CBD was not to be used in any food or beverages. The FDA has signaled that until further studies are provided or unless Congress rules that CBD is a supplement – it will continue to treat CBD as a medicine. This
regulatory uncertainty, in turn, significantly reduced retailer demand for any CBD products in late 2021 and increasingly into 2022.

Due to ongoing challenges for products containing CBD, the market capitalizations for CBD companies (including the Company)
dropped significantly in early 2022, even more so than the general reduction in the overall market capitalizations of most publicly traded companies. As a result of the ongoing regulatory uncertainty and the corresponding impact on market caps in
the industry, the Company recorded a goodwill impairment for its U.S. cannabis business of $25,169 and a brand impairment charge for its U.S. cannabis business of $4,630 as of June 30, 2022. As of December 31, 2022, there was further
erosion in the market values of the Company and other publicly traded CBD companies relating to the ongoing uncertainty regarding the regulatory status of CBD and the corresponding decline in retail sales of CBD products, which led to the Company
recording an additional goodwill impairment charge of $13,500, for total impairment charges for its U.S. cannabis business of $43,299 for the year ended December 31, 2022.

 - 3 -

 As of the dates of the impairment charges, the Company did not believe it
would be able to overcome the adverse factors that led to such charges because there was no indication that the FDA would change its position regarding CBD or that either the FDA or U.S. Congress would take regulatory and/or legislative steps toward
facilitating retail sales of CBD-infused food and beverages in the United States.

In response to the Staff’s comment, the Company will include in future filings a more specific discussion of impairment
charges in its discussion of “Critical Accounting Estimates” in its Management’s Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”) in accordance with the requirements of Item 303(a)(3) of
Regulation S-K.

 As an example, see Appendix A to this response letter,
which sets forth a proposed template of disclosure to be included in the MD&A – Critical Accounting Estimates section of the Company’s Quarterly Report on Form 10-Q for the quarter ended
June 30, 2023.

 Cannabis Segment Results - Canada, page 51

3.
 You state under “Cannabis Segment Results - Canada” that you present a discussion of the
operating results of Pure Sunfarms, before any allocation to Village Farms, which were not consolidated in your financial results for the period of January 1, 2020 to November 1, 2020, and were only consolidated in your results for the
years ended December 31, 2022 and 2021 and the period November 2, 2020 to December 31, 2020. As a result, we note your discussion of this segment’s results for the year ended December 31, 2021 compared to the year ended
December 31, 2020 as presented beginning on page 52 is not based on your GAAP results. Please revise this discussion to present and discuss your GAAP results.

Response

The Company acknowledges the Staff’s comment and respectfully submits that it had presented a 2021 vs 2020 year-over-year
comparison of the Canadian Cannabis segment using GAAP results for 2021 and including a full year of Pure Sunfarms in 2020 (vs its GAAP results, which would have only included Pure Sunfarms since its acquisition of November 1, 2020) in an
effort to illustrate the change in the underlying business without giving effect to the timing of the Pure Sunfarms acquisition (which prior to the acquisition had been an equity-accounted investment and in respect of which the Company had
previously filed financial statements in accordance with Rule 3-09 of Regulation S-X in its annual reports on Form 10-K for the
years ended December 31, 2019 and 2020). The Company’s presentation of this comparison was intended to provide investors with information regarding the actual performance of this business between periods.

The Company further respectfully submits that the Company did compare and discuss its consolidated GAAP income statement
between 2021 and 2020 on pages 49 to 51 of the 2022 Form 10-K, which preceded the comparison and discussion of the Canadian Cannabis segment results for 2021 and 2020.

 - 4 -

 However, in response to the Staff’s comment, in future filings, the
Company will present a comparison of its GAAP results for its discussion of both its consolidated and segment results in its Management’s Discussion and Analysis of Financial Condition and Results of Operations.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Non-GAAP Measures

Reconciliation of Net Income to Adjusted EBITDA, page 61

4.
 We have the following comments regarding your non-GAAP
measure, Adjusted EBITDA:

•

 Please reconcile the $7,136 provision for (recovery of) income taxes to the $4,681 reflected on your
consolidated statement of loss for the year ended December 31, 2022;

Response

The Company respectfully advises the Staff that the $4,681 reflected on the consolidated income statement includes 100% of the
(provision for) recovery of taxes attributable to the Company’s majority-owned consolidated subsidiary Rose LifeScience. The $7,136 adjustment excludes this tax effect from Rose LifeScience. An additional tax adjustment to
Adjusted EBITDA for the Company’s 70% share of Rose LifeScience is reflected in the Adjusted EBITDA table on the line, (Recovery of) provision for income taxes from JV’s. Please see Appendix
B-1, attached to this letter, which includes a copy of the as-filed Adjusted EBITDA reconciliation table included on page 61 of the 2022 Form 10-K, where we have highlighted these line items.

 In future filings, the Company will
separately provide adjustments for (1) provision for (recovery of) income taxes that align with the amount shown on the Company’s income statement, and, if applicable, (2) the tax effects attributable to joint ventures
and/or minority non-controlling interests.

 Please see Appendix B-2, attached to this letter, which includes an adjusted version of the table shown in Appendix B-1, which reflects the full income tax provision as an adjustment
to Adjusted EBITDA and corresponding adjustments to the provision for income taxes for income taxes from JVs and non-controlling interests.

The Company advises the Staff that it has addressed this comment on page 24 of the Q1 2023 Quarterly Report.

 - 5 -

•

 You include adjustments for inventory write-down to net realizable value and share of loss on JV
inventory impairment. Since inventory write-downs are normal expenses to operate your business, please tell us how you considered the guidance in Question 100.01 of the Compliance and Disclosure Interpretations on
Non- GAAP Financial Measures; and,

 Response

The Company acknowledges the Staff’s comment and respectfully submits that the
non-GAAP adjustments for “Loss on inventory write-down to net realizable value” and “Share of loss on JV inventory impairment” do not constitute “normal, recurring, cash operating
expenses necessary to operate a registrant’s business” within the meaning of Question 100.01 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. “Loss on inventory
write-down to net realizable value” of $11,038 in 2022 is distinguishable from inventory adjustments that the Company incurs on a normal, recurring basis, such as inventory that does not meet testing standards, is lost in the form of shrink in
the manufacturing process, test samples, damaged finished goods, etc. All of these types of inventory adjustments are a normal and necessary part of the Company’s agriculturally-based business and are included in cost of sales and are not added
back to arrive at a non-GAAP financial measure. By contrast, the large amount of inventory written down as a non-cash charge for the fourth quarter of 2022 was due to
the change in distribution from both retail and wholesale to just wholesale, which continues to suffer poor pricing conditions as discussed in our response to Comment #1 above, and therefore GAAP required the Company to revalue these assets. Unlike
ordinary course inventory adjustments, the write-down related solely to the market value of the inventory, which remains saleable or otherwise usable for other cannabis-derived products as part of the Company’s operations. For these reasons,
the Company believes it is appropriate and not misleading to treat the inventory write-down in 2022 as a non-GAAP adjustment, as this particular write-down is a one-time
non-cash adjustment. Furthermore, the Company considered the value of this inventory as of March 31, 2023 and concluded that no further write-downs of this nature were required.

“Share of loss on JV inventory impairment” of $2,284 relates to the final disposition of the Company’s 2019
hemp inventory that is no longer held for sale due to continuing FDA uncertainty regarding the use of CBD in food and beverages (as discussed in response to Comment #2 above) which led the Company to take steps towards winding down its VF Hemp joint
venture. The Company respectfully submits that this impairment charge is a non-cash charge and a non-recurring item outside of the ordinary course of operations. For
these reasons, the Company believes it is appropriate