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May 29, 2020
Amed Hazel
Manager
LB 1 LLC
818 Natchez Valley Trace
Grayson, GA 30017
Re:LB 1 LLC
Amendment No. 1 to
Offering Statement on Form 1-A
Filed May 14, 2020
File No. 024-11147
Dear Mr. Hazel:
            We have reviewed your amended offering statement 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.  Unless we note
otherwise, our references to prior comments are to comments in our February 26, 2020 letter.
Amendment No. 1 to Offering Statement on Form 1-A
General
1.We note your response to comment 2 and revised disclosure on page 6.  Please revise to
disclose the information required by Item 14(b) of Form 1-A.  In this regard we note, that
based on the secured promissory note interest will be due and paid in full on maturity
unless prepaid by you prior to maturity.  Additionally, we note the risk factor on page 19,
regarding the cash-out provision and the automatic extension if the note holder does not
provide 90 days notice.  Also, pursuant to the intercreditor security agreement note
holders acknowledge that the security for the notes is a prorated interest in the shares of
the company.  Your revised disclosure should address the material terms of the notes

 FirstName LastNameAmed Hazel
 Comapany NameLB 1 LLC
 May 29, 2020 Page 2
 FirstName LastName
Amed Hazel
LB 1 LLC
May 29, 2020
Page 2
being offered.  In this regard, we note on page 22 that you intend to provide note holders
with annualized returns that will vary from time to time.  Please tell us whether you intend
to change the interest rates of your notes based on the performance of your operations.
We may have further comment.
2.We note your response to comment 8 and revised disclosure on page 6.  We continue to
note that you have limited assets and no revenues or operating history.  It remains unclear
on what basis you state that returns are "expected to be in the range from 6% to 9%."
Please remove the target returns.
3.We note your revised disclosure and response to comments 3 and 8, including your
statement that you have business relationships with approximately 200 financial
institutions and plan to "secure a loan package of about 320 loans valued at approximately
$20M."  Please revise page 22 to address your planned operations.  Additionally, please
provide narrative disclosure of your prior performance.  For example, please provide
disclosure related to compensation and prior performance in accordance with Guide 5, as
applicable.  Please refer to Release No. 33-6900 (June 17, 1991) and Item 7(c) of Part II
of Form 1-A, and CF Disclosure Guidance Topic No. 6.
Plan of Operation, page 22
4.We note your revised disclosure and response to comments 2 and 4.  Please revise to
provide detailed disclosure of your management strategy, including with respect to
trading, leverage and your financing strategy.  For example, it is unclear if and how you
intend to match assets and liabilities with respect to interest rate and maturity.  It is also
unclear if and how you plan to actively trade in mortgage securities, acquire and manage a
portfolio of mortgage securities or conduct other operations.
Audited Financial Statements, page 39
5.We note your disclosure on page 23 and 44 that the Company’s fiscal year-end is
December 31.  Please revise your filing to update your financial statements through
December 31, 2019.  See Form 1-A, Part F/S (b)(3)(A) and (4).
Part III - Exhibits, page 48
6.We note that the last sentence of the accountant’s consent (Exhibit 11.2) refers to the
financial statements of Own Our Own Fund I, LLC instead of LB 1 LLC.  Please have
your accountant revise his consent to correct this discrepancy.

 FirstName LastNameAmed Hazel
 Comapany NameLB 1 LLC
 May 29, 2020 Page 3
 FirstName LastName
Amed Hazel
LB 1 LLC
May 29, 2020
Page 3
            You may contact Jorge Bonilla at 202-551-3414 or Robert Telewicz at 202-551-3438 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Jonathan Burr at 202-551-5833 or James Lopez at 202-551-3536 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction