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June 12, 2023
Joshua Goldstein
General Counsel and Secretary
Masterworks Vault 1, LLC
225 Liberty Street, 29th Floor
New York, New York 10281
Re:Masterworks Vault 1, LLC
Post-Qualification Amendment No. 2 to Offering Statement on Form 1-A
Filed June 8, 2023
File No. 024-12098
Dear Joshua Goldstein:
            We have reviewed your amended offering statement and have the following comment.  In
our comment, 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 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 comment, we may have additional comments.
Post-Qualification Amendment No. 2 to Offering Statement on Form 1-A
Report of Independent Auditors, page F-2
1.Please have your auditor revise their report to opine on the financial statements
for Masterworks Vault 1, LLC in total and each Series.  Further, ask them to revise their
report to also state, if true, that they are required to be independent with respect to you in
accordance with U.S. federal securities laws and the applicable rules and regulations of
the Securities and Exchange Commission.  Finally, they should state the specific period
that was audited – inception (November 9, 2022) through December 31, 2022.  Refer to
paragraph (c)(1)(iii) in Part F/S of Form 1-A, Article 2 of Regulation S-X and paragraphs
.25(e), .28(c), .A38 and .A39 of AU-C Section 700 of the Statements on Auditing
Standards.  Our comment also applies to your annual reports.

 FirstName LastNameJoshua Goldstein
 Comapany NameMasterworks Vault 1, LLC
 June 12, 2023 Page 2
 FirstName LastName
Joshua Goldstein
Masterworks Vault 1, LLC
June 12, 2023
Page 2
            You may contact Patrick Kuhn at 202-551-3308 or Rufus Decker at 202-551-3769 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Taylor Beech at 202-551-4515 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services