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November 29, 2023
Patrick Horgan
Chief Executive Officer
Cub Crafters, Inc.
1918 South 16th Avenue
Yakima, WA 98903
Re:Cub Crafters, Inc.
Offering Statement on Form 1-A
Post Qualification Amendment No. 1
Filed November 3, 2023
File No. 024-11983
Dear Patrick Horgan:

            We have reviewed your amendment and have the following  comment(s).
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Post Qualification Amendment to Form 1-A filed November 3, 2023
SUMMARY INFORMATION, page 1
1.Please highlight in this section that investors purchasing securities in this offering will
only hold a maximum of 4.13% of your company's voting power, given that holders of
your Class B Common Stock are entitled to eight votes per share.
Use of Proceeds, page 21
2.Your disclosure that the maximum gross proceeds from the sale of the securities in this
Offering are $50 million is inconsistent with the $54.5 million reflected in the 100%
column. Please advise or revise.
General

 FirstName LastNamePatrick Horgan
 Comapany NameCub Crafters, Inc.
 November 29, 2023 Page 2
 FirstName LastName
Patrick Horgan
Cub Crafters, Inc.
November 29, 2023
Page 2
3.We note that the Series A Preferred Stock are convertible into Common Stock upon the
date of the occurrence of events specified by the holders of a majority of the then
outstanding shares of Series A Preferred Stock.  Please expand your disclosure to discuss
whether the holders of the majority of Series A Preferred Stock have specified any events
for conversion.
4.Please disclose, wherever applicable, that future issuances of your Class B Common Stock
will be dilutive to holders of your Series A Preferred Shares and holders of your Class A
Common Stock. Please include appropriate a risk factor disclosure related to the potential
dilution.
            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 Charles Eastman at 202-551-3794 or Hugh West at 202-551-3872 if you
have questions regarding comments on the financial statements and related matters. Please
contact Bradley Ecker at 202-551-4985 or Asia Timmons-Pierce at 202-551-3754 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing