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        PROCOPIO

        12544 High Bluff Drive

        Suite 400

        San Diego, CA 92130

        T. 858.720.6300

        F. 619.235.0398

    DEL MAR HEIGHTS

Las Vegas

PHOENIX

SAN DIEGO

SILICON VALLEY

April 30, 2020

VIA EDGAR

    Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-3720

 Attention: Scott Anderegg

   Jennifer Lopez-Molina

 Re: My Racehorse CA LLC

Offering Statement on Form 1-A Post Qualification Amendment No. 9

   Filed April 7, 2020

   File No. 024-10896

Ladies and Gentlemen:

On behalf of our client,
My Racehorse CA LLC (the “Company”), we submit this letter in response to comments from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) contained in its letter dated April 15, 2020, relating
to the Company’s Post-Qualification Amendment No. 9 to Offering Statement on Form 1-A (File No. 024-10896) filed with the
Commission on April 7, 2020 (“Post-Qualification Amendment No. 9”). We are concurrently filing via EDGAR this
letter and the Company’s Post-Qualification Amendment No. 10 to Offering Statement on Form 1-A (File No. 024-10896) (“Post-Qualification
Amendment No. 10”).

In this letter, we
have recited the comments from the Staff in italicized, bold type and have followed each comment with the Company’s response.
Except for page references appearing in the headings and comments of the Staff below (which are references to Post-Qualification
Amendment No. 9 filed on April 7, 2020), or as otherwise specifically indicated, all page references herein correspond to the page
of Post-Qualification Amendment No. 10.

Post Qualification Amendment
No. 9 to Form 1-A

Financial Statements, page
F-1

        procopio.com

Securities and Exchange Commission

April 30, 2020

Page 2

 1. Please update your financial statements and management’s discussion and analysis of financial condition and results
of operations for the year ended December 31, 2019, as required by Part F/S (b)(3)(A) of Form 1-A. As a related matter, please
update your executive compensation section for the most recently completed fiscal year end to comply with Item 11 of Form 1- A.

In response to the Staff’s comment,
the Company has updated its financial statements, management’s discussion and analysis of financial condition and results
of operations and executive compensation for the year ended December 31, 2019 and included them in Post-Qualification Amendment
No. 10 being filed concurrently herewith.

Exhibit 12.1

Legal Opinion, page II-2

 2. Please have counsel opine whether purchasers of the Interest will have any obligation to make payments to the limited
liability company or its creditors (other than the purchase price for the Interests) or contributions to the limited liability
company or its creditors solely by reason of the purchasers' ownership of the Interest. Refer to Staff Legal Bulletin No. 19, Section
II.B.1.b.

In response to the Staff’s
comment, the Company has updated its legal opinion to comport with Staff Legal Bulletin No. 19, Section II.B.1.b. and
attached it as Exhibit 12.1 to the Post-Qualification Amendment No. 10.

****

Please direct any questions regarding the
Company’s responses or Post-Qualification Amendment No. 10 to the Offering Statement to me at (858) 720-6320 or
christopher.tinen@procopio.com.

    Sincerely,

    PROCOPIO, CORY, HARGREAVES & SAVITCH LLP

    /s/Christopher L. Tinen, Esq.

    Christopher L. Tinen, Esq.

    cc:
    Michael Behrens, My Racehorse CA LLC

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