SecProbe.io

CORRESP
1
filename1.htm

ANTHONY
L.G., PLLC

    laura
        aNTHONy, esq

        GEOFFREY
        ASHBURNE, ESQ*

        JOHN
        CACOMANOLIS, ESQ**

        CHAD
        FRIEND, ESQ, LLM

        SVETLANA
ROVENSKAYA, ESQ***

    WWW.ANTHONYPLLC.COM

        WWW.SECURITIESLAWBLOG.COM

        WWW.LAWCAST.COM

                                                         OF
        COUNSEL:

        MICHAEL
        R. GEROE, ESQ, CIPP/US****

        CRAIG
        D. LINDER, ESQ*****

        PETER
        P. LINDLEY, ESQ, CPA, MBA

        PHILIP
        MAGRI, ESQ.******

        STUART
        REED, ESQ

        MARC
S. WOOLF, ESQ

        DIRECT
        E-MAIL: LANTHONY@ANTHONYPLLC.COM

*
licensed in CA only

**licensed
in FL and NY

***licensed
in NY and NJ

****licensed
in FL, CA and NY

May
8, 2020

VIA
ELECTRONIC EDGAR FILING

Office
of Trade & Services

Division
of corporate Finance

Securities
and Exchange Commission

100
F. Street, N.E.

Washington,
D.C. 20549

    Re:
    Masterworks
        009, LLC

        Offering Statement on Form 1-A

        Filed
        April 2, 2020

        File
        No. 024-11185

Dear
Sir or Madam:

We
have electronically filed herewith on behalf of Masterworks 009, LLC (the “Company”) Amendment No. 1 (“Amendment
No. 1”) to the above-referenced offering statement on Form 1-A originally filed on April 2, 2020 (“Form 1-A”).
Amendment No. 1 is marked with < R > tags to show changes made from the original filing of the Form 1-A filed on April 2,
2020. In addition, we have included a narrative response herein keyed to the comments of the staff of the Division of Corporation
Finance (the “Staff”) set forth in the Staff’s comment letter to Josh Goldstein dated April 30, 2020. We trust
you shall deem Amendment No. 1 and the contents of this transmittal letter responsive to your comment letter.

Cover
Page, page 1

    1.
    Comment:
    We note your statement that you will not accept subscriptions prior to your filing of an amendment or supplement identifying
    the specific art work you will purchase. Please advise us whether you will be receiving (although not accepting) subscriptions
    prior to your filing of an amendment or supplement identifying the specific art work you will purchase. In this regard, your
    references to “amendment or supplement” are unclear; please also revise to clarify that you will identify the
    artwork, and file the definitive agreement to acquire the artwork, in an amendment to this offering statement prior to qualification
    of this offering or tell us why you believe a post-qualification amendment or supplement is consistent with your disclosure
    that that you will not accept subscriptions before identifying the artwork.

Response: In response to
the Staff’s comment, the Company has revised the relevant disclosure in Amendment No. 1 to clarify that it will identify
the artwork, and file the definitive agreement to acquire the artwork, in an amendment to the offering statement prior to qualification
of the offering. The Company will not receive or accept any subscription funds or executed subscription agreements until a
pre-qualification amendment has been filed and qualified by the SEC. The Company intends to request qualification of the Offering
Statement only after it has identified the Painting and filed a definitive agreement to acquire the artwork.

The Company further informs
the Staff that it has removed information about the Artist and the Painting from Amendment No. 1 and has indicated that such information
will be inserted in an amendment to the Offering Circular prior to the qualification of the offering, when a Painting
has been identified and the terms of purchase have been determined.

Organizational
Structure, Page 6

    2.
    Comment:
    We note that you have listed some broad categories of risk factors applicable to an investment in your offering. Item
    3 of Form 1-A requires a carefully organized series of short, concise paragraphs, summarizing the most significant factors
    that make the offering speculative or substantially risky. Please revise.

Response:
In response to the Staff’s Comment, the Company has replaced the abbreviated bullet-point risk factors, with a more fulsome
summary risk factor discussion on page 6 of Amendment No. 1.

If
the Staff has any further comments regarding the form 1-A or any subsequent amendments to the Company’s offering statement
on Form 1-A, please feel free to contact the undersigned.

    Anthony L.G., PLLC

    By:
    /s/
    Laura Anthony

    Laura Anthony, Esq.

    cc:
    Scott Anderegg/U.S. Securities and Exchange
    Commission

    Mara Ransom/U.S. Securities and Exchange Commission

    Joshua
    B. Goldstein/Masterworks 009, LLC

     Craig D. Linder, Esq./Anthony L.G., PLLC

625
N. FLAGLER DRIVE, #600 ● WEST PALM BEACH, FLORIDA ● 33401 ● PHONE: 561-514-0936 ● FAX 561-514-0832