SecProbe.io

January 22, 2020
Julio Macedo
Manager
American Diversified Energy LLC
711 W. 17th Street, Suite D-5
Costa Mesa, CA 92627
Re:American Diversified Energy LLC
Amendment Nos. 4 and 5 to Offering Statement on Form 1-A
Filed January 9 and 14, 2020
File No. 024-10904
Dear Mr. Macedo:
            We have reviewed your amended offering 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 offering 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 offering statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our December 2, 2019 letter.
Form 1-A Amendment No. 5 filed January 14, 2020
Results of Operations, page 91
1.Reference is made to comment 6 and your revised disclosure provided in the first
paragraph on page 91.  Your disclosure of a net loss for the year ended October 31, 2018
and 2017 of $1,214,982 and $307,265 is consistent with the net loss reported on your
statements of operations.  However, your disclosure of incurred losses of $682,285 and
$373,203 for the nine months ended July 31, 2019 and 2018 is not consistent with the net
loss reported on your statements of operations.  Please revise.

 FirstName LastNameJulio Macedo
 Comapany NameAmerican Diversified Energy LLC
 January 22, 2020 Page 2
 FirstName LastName
Julio Macedo
American Diversified Energy LLC
January 22, 2020
Page 2
Liquidity and Capital Resources, page 92
2.In the fifth paragraph you refer to a liability of $957,000 to ADE Crescent while the
balance sheet presents a liability of $976,650.  Please explain or revise.
Financial Statements, page F-1
3.In a note or separate statement, please provide an analysis of the changes in each caption
of members’ deficit presented in the balance sheet as of July 31, 2019.  Reference is made
to (b)(5), Part F/S of Form 1-A.
Note 10 - Subsequent Events
Investment of Corvette, LLC in ADE Crescent City LLC and Summary of the Amended
Restated Operating Agreement of ADE Crescent City LLC, page F-26
4.We are reissuing comment 14 in light of the Form 1-A/A filed January 14, 2020.  Your
response to comment 14 states ADE Crescent was in the construction stage and did not
exceed the 20% threshold in Rule 8-03(b)(3) of Regulation S-X.  However, subsequent to
your response, in Form 1-A/A filed January 14, 2020, the balance sheet presents an equity
method investment balance of $334,455, which exceeds 20% of your consolidated assets.
Please revise to provide the required Rule 8-03(b)(3) of Regulation S-X disclosure or
explain why such disclosure is not required.
5.You disclose that management determined that the receivable recorded on ADE Crescent
City books and records of $976,000 is likely not recoverable from the Company.  Please
disclose the bad debt expense recorded.
            You may contact Scott Stringer at (202) 551-3272 or Adam Phippen at (202) 551-3336 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Daniel Morris at (202) 551-3314 or Mara Ransom, Office Chief, at (202) 551-3264 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Kristin Cano, Esq.