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CORRESP
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    Anthony
                                         F. Geraci*

        Christina
        L. Geraci

        Nema
        Daghbandan

        Kevin
        S. Kim

        Paul
        J. Sievers

        Dennis
        R. Baranowski

        Amy
        E. Martinez

        Melissa
        C. Martorella

        Alexa
        P. Stephenson

        Bryan
        P. Redington

        90
        Discovery

        Irvine,
        California 92618

        www.geracilawfirm.com

    Aruna
Hatti**

        Alexandra
        Anast

        Larissa
        Branes

        Mustafa
        Kadri

        Kyle
        Niewoehner

        Tae
        K. Kim

        Bibin
        Mannattuparampil***

        *
        Admitted in Arizona &New Jersey

        **Admitted
        in New York & Washington D.C. Only

        ***Admitted
        in Florida Only

Via
EDGAR and OVERNIGHT MAIL

Mr.
Jonathan Burr and Ms. Pamela Long

Division
of Corporate Finance - Office of Real Estate & Commodities

100
F Street, N.E.

Washington
D.C. 20549

March
12, 2020

 Re: CIRCLE
                                         OF WEALTH FUND III LLC

Offering
Statement on Form 1-A

Post-Qualification
Amendment No. 1

FILE
NO. 024-10948

Dear
Mr. Burr and Ms. Long:

This
letter is submitted on behalf of CIRCLE OF WEALTH FUND III LLC (the “Company”) in response to comments from the staff
of the Division of Corporate Finance (the “Staff”) of the Securities & Exchange Commission (the “Commission”)
in a letter dated February 25, 2020 (the “Comment Letter”) with respect to the Company’s Offering Statement
on Form 1-A, Post-Qualification Amendment No. 1 (File No. 024-10948) submitted for review pursuant to Regulation A under the Securities
Act of 1933, as amended. The submission is in connection with the Offering Statement submitted to the Commission on February 13,
2020, relating to the Company’s offering of up to $50,000,000 in membership interests, as well as, the rescission offering
to the existing members (collectively, the “Offering Statement”). The responses provided are based upon information
provided to Geraci Law Firm by the Company. The Company is concurrently filing the Offering Statement (the “Amended Submission”),
which includes amendments and revisions in response to the Staff’s comments as well as additional revisions and amendments.

For
your convenience, the Staff’s numbered comments set forth in the Comment Letter have been reproduced in italics herein with
responses immediately following each comment. Unless otherwise indicated, page references in the descriptions of the Staff’s
comments refer to the Offering Statement, and page references in the responses refer to the Amended Submission. Defined terms
used herein but not otherwise defined have the meanings given to them in the Amended Submission.

Re: Response Letter

March 12, 2020

Page 2

Comment
No. 1

1.
Please revise to reduce the amount of your best efforts offering by the aggregate amount of securities sold pursuant to the offering
statement in the prior 12 month period. Please see Rule 251(a) of Regulation A and Instruction 1 to Form 1-A for guidance.

Response
to Comment No. 1

In
response to the Staff’s comment, the Company has revised to reduce the amount of the best efforts offering by the aggregate
amount of securities already sold pursuant to the Offering Statement in the prior 12-month period. The current maximum offering
amount is adjusted to $49,375,000.

Comment
No. 2

2.
You have omitted the footnotes to your interim financial statements for the six months ended June 30, 2019. Please revise to include
the footnotes, as required by U.S. GAAP and Article 8-03(b) of Regulation S-X. Please also ensure that your audited and interim
financial statements are included in the body of the offering circular, rather than as an exhibit.

Response
to Comment No. 2

In
response to the Staff’s comment, we have updated the Company’s financials to include the audited financial statements
as of December 31, 2019. The financial statements for the six months ended on June 30, 2019 was removed and replaced with the
audited financial statements. The audited financials include comments and notes pertaining to the financial statements for the
period of December 31, 2019. Accordingly, the Company believes that this request is moot. Please see the section “Index
to Financial Statements” beginning in F-1 of the Offering Circular.

Comment
No. 3

3.
Where you describe how investors will receive and accept the rescission offer, please clarify whether the email will include a
link to the offering circular. We note that your disclosure indicates the email will include “an outline of the offer.”

Response
to Comment No. 3

In
response to Staff’s comments, the email will include a link to the offering circular, and an outline of the offer will be
included in that email. As part of that email, we will request that the investors complete and return the “Form of Rescission
Offer Election” to the Company via email address or snail mail.

Re: Response Letter

March 12, 2020

Page 3

Comment
No. 4

4.
We note that you intend to use a portion of the net proceeds from your primary offering and proceeds from business operations
to fund the rescission offer. In this regard, on page 44 you disclose that the sale of your membership interests was suspended
when you identified the omission. Additionally, on page 34 you disclose that you have $25,000 and plan to sell membership interests
on a needed basis to operate your business. Please disclose how you expect to fund the rescission offer and discuss the impact
of the offer on your operations. Additionally, update your use of proceeds disclosure to indicate the amount of proceeds being
used to fund the rescission offer.

Response
to Comment No. 4

In
response to the Staff’s comment, and in reference to the response to Comment No. 2 above, the Company has included the audited
financial statements ending in period of December 2019. The audited financial statements indicate sufficient assets to fund the
rescission offer with total assets in the amount of $640,675. The Company intends to use cash and cash equivalents, as well as
other assets, to fund such offers.

Comment
No. 5

5.
Disclosure on page 37 refers to prior performance tables, however, you have not included the prior performance tables with this
post-qualification amendment. Please revise to include this information.

Response
to Comment No. 5

In
response to the Staff’s comment, the Company has included the prior performance tables with the post-qualification amendment.
Please see pages 37-45 of the Offering Circular.

    Best
    Regards,

    /s/
    Kevin S. Kim

    Kevin
    S. Kim, Esq.

    Partner

    Corporate
    & Securities Division

    Geraci
    Law Firm.