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July 11, 2023
Nick King
Chief Executive Officer
VV Markets LLC
2800 Patterson Ave Ste. 300
Richmond, VA 23221
Re:VV Markets LLC
Offering Statement on Form 1-A
Post-Qualification Amendment No. 11
Filed June 14, 2023
File No. 024-11306
Dear Nick King:
            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. 11 to Offering Statement on Form 1-A Filed June 14, 2023
The Underlying Assets, page 38
1.We note that you have purchased and intend to purchase a number of underlying assets
from Liv-Ex.  We also note that you rely on Liv-Ex for secondary market pricing data for
wine and spirits and for insurance for your assets.  Please add a risk factor that addresses
the conflicts of interest and if material, please quantify the amount of business that you do
with Liv-Ex for the periods represented in this offering statement.
The Series VV-SCC2 Asset, page 132
2.We note your amended disclosure in response to comment 1.  With respect to the
information provided for Series VV-SCC2, please define "Acquisition Average Price per
Bottle."  In this light, we note that this series is comprised of nine individual bottles, each

 FirstName LastNameNick King
 Comapany NameVV Markets LLC
 July 11, 2023 Page 2
 FirstName LastName
Nick King
VV Markets LLC
July 11, 2023
Page 2
with their own Acquisition Average Price per Bottle.  However, we note that the
cumulative average price of all of the assets in the series is $113,042.00, but the actual
purchase price to acquire the assets is $96,085.76.  Please provide an explanation for this
difference.
General
3.We note the receipt of a Purchase Agreement with Purchase Order between VV Markets,
LLC and Vinvesto, Inc. submitted to us supplementally, and that you propose to file
similar Purchase Agreements/Purchase Orders for the various underlying assets.
However, it appears that the Purchase Order is generated by Vinvesto, Inc. and is not a
receipt for, or contract or agreement with, the supplier for the underlying asset, which in
this case is Liv-Ex.  The Purchase Order also does not appear to include certain material
information related to shipping, storage, discounts, etc., that may be included in the
receipt, contract, or agreement with the supplier.  Please file as exhibits to the Offering
Statement the receipts, contracts, or agreements received from, or entered into with, the
supplier.
            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 Cara Wirth at 202-551-7127 or Erin Jaskot at 202-551-3442 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Andrew Stephenson