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November 8, 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. 25 to Form 1-A
Filed October 28, 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. 25 to Form 1-A
Description of Business
Liquidity Platform, page 75
1.On page 75, you disclose that your Liquidity Platform “enables investors to buy and sell
their holdings via the PPEX ATS,” and that the Liquidity Platform “serves as the user
interface through which interest holders and prospective secondary purchasers submit
orders to buy or sell interests in a series of our company.”  As the Liquidity Platform
appears to provide a market place for bringing together purchasers and sellers of
securities, please tell us why you would not fall within the definition of an exchange under
Section 3(a)(1) of the Exchange Act and Rule 3b-16(a) thereunder.  In your response,
please describe how the Liquidity Platform enables the making of a secondary market in
your securities; for example, by quoting prices.

 FirstName LastNameKeith Marshall
 Comapany NameOtis Gallery LLC
 November 8, 2021 Page 2
 FirstName LastName
Keith Marshall
Otis Gallery LLC
November 8, 2021
Page 2
2.You also indicate on page 75 that “the Liquidity Platform functions to deliver information
to investors, the Broker and the PPEX ATS, and display information to investors.”  Please
describe what information is delivered and displayed to investors, the Broker, and the
PPEX ATS, the manner in which it is displayed, and who is displaying it (i.e., the
Liquidity Platform or PPEX ATS).  Please explain the circumstances under which an
order or paired orders are sent to the PPEX ATS and if orders are maintained within the
Liquidity Platform.  Please explain how, if at all, an investor, for example, may submit an
order to the PPEX ATS without using the Liquidity Platform.
3.You indicate on page 75 that “[a]ll rules for the Liquidity Platform are set in conjunction
with the Broker and North Capital Private Securities within the parameters of the
applicable regulatory requirements and the PPEX ATS.”  Please identify and explain the
rules that are set in conjunction with the Broker and North Capital and how such rules
apply to investors use of the Liquidity Platform, Broker, and PPEX and their trading of
your securities.
4.In addition, you indicate on page 75 that “[t]he Otis Platform merely acts as a user
interface to facilitate the functionality of the PPEX ATS.”  Please describe how the
Liquidity Platform facilitates the functionality of the PPEX ATS.
            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.
            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