SecProbe.io

March 20, 2020
Joshua B. Goldstein
General Counsel
Masterworks 007, LLC
497 Broome Street
New York, New York 10013
Re:Masterworks 007, LLC
Offering Statement on Form 1-A
Filed February 26, 2020
File No. 024-11161
Dear Mr. Goldstein:
            We have reviewed your 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.
Offering Statement on Form 1-A filed February 26, 2020
Dilution , page 27
1.We are unable to compute the number and percentages of shares of Class A common
stock Masterworks would receive upon conversion of 100% of the Class B shares based
on the amounts presented in the table at the bottom of the page and the formula for the
conversion.  Please show us how you computed the amounts disclosed assuming the
hypothetical Class A share values presented.  In addition, if the hypothetical Class A share
values presented do not represent the assumed VWAPs please revise to disclose the
assumed VWAPs rather than the hypothetical Class A share values presently disclosed.
Exhibits
2.We note that Section 11 of the form of subscription agreement contains a jury waiver
provision.  Please revise your disclosure in the offering circular to describe the provision

 FirstName LastNameJoshua B. Goldstein
 Comapany NameMasterworks 007, LLC
 March 20, 2020 Page 2
 FirstName LastName
Joshua B. Goldstein
Masterworks 007, LLC
March 20, 2020
Page 2
and to state, as you do in the agreement, that it does not apply to claims under the federal
securities laws.
3.We note that you have relied and expect that investors will rely on the appraisal that is
attached as an exhibit to the Intercompany Agreement.  Please file an appraiser’s consent
as contemplated by Item 17, paragraph 11, of Form 1-A, or tell us why you are not
required to do so.
            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.  We also remind you that, following qualification of your Form 1-A, Rule 257
of Regulation A requires you to file periodic and current reports, including a Form 1-K which
will be due within 120 calendar days after the end of the fiscal year covered by the report.
            You may contact Robert Shapiro at (202) 551-3273 or Bill Thompson at (202) 551-3344
if you have questions regarding comments on the financial statements and related
matters.  Please contact Daniel Morris at (202) 551-3314 or Lilyanna Peyser at (202) 551-3222
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Laura Anthony, Esq.