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    PROCOPIO

12544 High Bluff Drive

Suite 400

San Diego, CA 92130

    T. 858.720-6300

    F. 619.235.0398

    CHRISTOPHER TINEN

    P. 858.720.6320

    christopher.tinen@procopio.com

    DEL MAR HEIGHTS

    LAS VEGAS

    ORANGE COUNTY

    PHOENIX

    SAN DIEGO

    SILICON VALLEY

    WASHINGTON D.C.

December 28, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549-3720

    Attention:

    Kate Beukenkamp

    Erin Jaskot

    Re:
    My Racehorse CA LLC

Offering Statement on Form 1-A

Post-qualification Amendment No. 16

Filed December 12, 2023

File No. 024-11808

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 December 26, 2023, relating
to the Company’s Post-Qualification Amendment No. 16 to Offering Statement on Form 1-A (File No. 024-11808) filed with the Commission
on December 12, 2023 (“Post-Qualification Amendment No. 16”). We are concurrently filing via EDGAR this letter and
the Company’s Post-Qualification Amendment No. 17 to Offering Statement on Form 1-A (File No. 024-11808) (“Post-Qualification
Amendment No. 17”).

      1

Securities and Exchange Commission

December 28, 2023

Page 2 of 2

In this letter, we have recited
the comment from the Staff in italicized, bold type and have followed such comment with the Company’s response. All page references
or capitalized terms herein correspond to the page of Post-Qualification Amendment No. 16.

Post-Qualification Amendment No. 16 to Offering
Statement on Form 1-A Filed on December 12, 2023

General

 1. We note your disclosure in the Use of Proceeds - Series the New York Bundle and Use of Proceeds
- Series Incredi-bundle discussing minority investments in Experiential Squared, Inc., the Manager, by Reeves Thoroughbred Racing,
LLC and Rocket Ship Racing, LLC, respectively. Please revise your disclosure to expand your discussion of these relationships and investment
interests. Specifically, update your Risk Factors section and related party disclosure as appropriate to account for these relationships
as well as disclose any monetary or other benefits Reeves and Rocket Ship may receive as a result of their respective relationships with
the Manager. We note your current disclosure, including a risk factor on page 27 regarding Spendthrift Farm LLC, an entity
that previously held a majority interest in the Manager. statement that "[i]n many instances, said lender will have a right, prior
to completion of the Offering, to participate in pre-closing dividends from revenue generated by its interest in the Underlying Asset
and the right to convert into the unsold portion of the offering prior to being fully funded." Please describe the types of revenue
that may be generated by the lender's interest in the Underlying Asset prior to being fully funded. Please revise your disclosure on page
130 as well.

In response to the Staff’s
comment, the Company has revised the Post-Qualification Amendment No. 17 accordingly to address said comment. As noted therein, the Company
has added a risk factor and added further disclosures related to such parties’ minority investment interests in Manager. The Company
previously assessed related party matters and whether a separate related party disclosure was appropriate and determined they were not,
given such investors currently hold only non-voting convertible instruments into the Manager that, respectively, will amount to less than
5% of the equity ownership of Manager and such rights do not contain any other preferential terms, monetary benefits, board seats, etc.
As such, these transactions were not deemed related party transactions.

***

Please direct any questions regarding the Company’s
response 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