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August 1, 2023
Michael Behrens
Chief Executive Officer
My Racehorse CA LLC
120 Kentucky Ave., Suite 110
Lexington, Kentucky 40502
Re:My Racehorse CA LLC
Offering Statement on Form 1-A
Post-Qualification Amendment No. 11
Filed July 6, 2023
File No. 024-11808
Dear Michael Behrens:
            We have reviewed your amendment 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.
Post-Qualification Amendment No. 11 to Offering Statement on Form 1-A Filed July 6, 2023
Series may only own a minority interest in Underlying Assets ..., page 22
1.We note your response to comment 7 and we reissue it in part.  Please address the
minority/majority interest raised in the "Series may only own a majority interest in the
Underlying Assets" risk factor.  Additionally, please revise your disclosure throughout the
offering circular for consistency and accuracy in this regard.  Also disclose who among
the co-owners of a Series is responsible for executing decisions, once such decisions are
made.  Finally, disclose who among the co-owners of a Series makes non-major decisions,
including the daily maintenance and care of the horse.
Potential Conflicts of Interest, page 25
2.We note your response and amended disclosure in response to comment 8 and we reissue

 FirstName LastNameMichael Behrens
 Comapany NameMy Racehorse CA LLC
 August 1, 2023 Page 2
 FirstName LastNameMichael Behrens
My Racehorse CA LLC
August 1, 2023
Page 2
it in part.  Please revise your disclosure that states that "[t]his conflict of interest will exist
in connection with Company management" to clarify what conflict of interest is being
described and between whom it exists.
Plan of Operations, page 123
3.We note your response to comment 11 and reissue it. Here, or elsewhere as appropriate,
please disclose the total amount of distributable cash and include how many horses and
races are responsible for such distributions to investors.
Description of the Business, page 130
4.We note your response and amended disclosure in response to comment 13. Please revise
your statement that "[t]he Company, in collaboration with the manager, Experiential, has
quickly emerged as one of the most successful stables in horse racing over the past several
years" to reflect that this is management's belief.
Executive Officers, Directors and Significant Employees of the Manager, page 142
5.We note your response to comment 16.  Please revise the table on page 142 to reflect the
approximate hours per week of the part-time employees/consultants.
Report of Independent Registered Public Accounting Firm, page F-1
6.Please have your auditor revise their report on page F-1 to also state, if true, that they are
required to be independent with respect to you and each listed Series in accordance with
U.S. federal securities laws and the applicable rules and regulations of the Securities and
Exchange Commission. Refer to paragraph (c)(1)(iii) in Part F/S of Form 1-A, Article 2 of
Regulation S-X and paragraphs .28(c), .A38 and .A39 of AU-C Section 700 of the
Statements on Auditing Standards. Our comment also applies to your future annual
reports.
General
7.We note your responses to comments 20 and 21. We continue to evaluate certain aspects
of your responses and may have further comments.
8.We note your response to comment 21.  Please clarify whether the securities offered by
Series Edge in the corresponding Regulation D offerings are identical to the securities
being offered pursuant to Regulation A and disclose and explain any material differences
in the rights of the respective securityholders.
9.With respect to any securities offered by Series Edge, please revise the applicable Use of
Proceeds tables to note any material amount of other funds that are to be used in
conjunction with the proceeds. Please state the amounts, sources of such other funds, and
whether such funds are firm or contingent. Refer to Instruction 5 to Item 6 of Part II of
Form 1-A.

 FirstName LastNameMichael Behrens
 Comapany NameMy Racehorse CA LLC
 August 1, 2023 Page 3
 FirstName LastName
Michael Behrens
My Racehorse CA LLC
August 1, 2023
Page 3
10.We note your disclosure in Part I, Item 6, Unregistered Securities Issued or Sold Within
One Year.  Please revise the corresponding exhibit, filed as exhibit 16.1, to itemize, on a
series-by-series basis, the amount of securities issued and the individual prices and/or
consideration received.
            We will consider qualifying your offering statement at your request.  If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Ta Tanisha Meadows at 202-551-3322 or Angela Lumley at 202-551-
3398 if you have questions regarding comments on the financial statements and related
matters.  Please contact Cara Wirth at 202-551-7127 or Dietrich King at 202-551-8071 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Christopher Tinen