SecProbe.io

United States securities and exchange commission logo
September 27, 2021
Keith Marshall
General Counsel
Otis Gallery LLC
335 Madison Ave, 16th Floor
New York, NY 10017
Re:Otis Gallery LLC
Post-Qualification Amendment No. 23 to Form 1-A
Filed September 17, 2021
File No. 024-10951
Dear Mr. Marshall:
            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. 23 to Form 1-A
Table, page ii
1. Please revise to provide prominent and clear disclosure of which series is being added in
this post-qualification amendment to the offering table on page ii
Series Offering Table, page v
2.Please revise to clarify the difference between an "Open" offering and an offering with
"No Sales Yet." In addition, please revise the table to specify the qualification date of
each offering and the day in which offers and sales commence or launch for each
offering.
            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

 FirstName LastNameKeith Marshall
 Comapany NameOtis Gallery LLC
 September 27, 2021 Page 2
 FirstName LastName
Keith Marshall
Otis Gallery LLC
September 27, 2021
Page 2
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.
            Please contact Jacqueline Kaufman at 202-551-3797 or Erin Jaskot at 202-551-3442 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services