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United States securities and exchange commission logo
March 13, 2024
Alan Snyder
Chief Executive Officer
aShareX Fine Art, LLC
10990 Wilshire Blvd., Suite 1150
Los Angeles, CA 90024
Re:aShareX Fine Art, LLC
Post Qualification Amendment No. 1 to Form 1-A
Filed February 16, 2024
File No. 024-12351
Dear Alan Snyder:
            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 No. 1 to Form 1-A filed February 16, 2024
Item 4 of Form 1-A, Part I, page iii
1.Refer to Item 4 to Form 1-A bullet point 15 which states "The portion of the aggregate
offering price attributable to all the securities of the issuer sold pursuant to a qualified
offering statement within the 12 months before the qualification of this offering
statement." Please revise to include your original November 2023 offering in the
calculation.
aShare Fine Art Series 11, page 4
2.We note footnote 2 to the chart, which states "The Asset Manager will serve as auctioneer
for the auction associated with the Artwork for aShareX Fine Art Series 11, and will be
compensated a commission equal to 15% of the Hammer Price. See “Management
Compensation” below for further details." Please advise us whether the Asset Manager is
a registered broker or advise how they they qualify under the safe harbor of Exchange Act
Rule 3a4-1, specifically Rule 3a4-1(a)(2) which states "[i]s not compensated in connection
with his participation by the payment of commissions or other remuneration based either

 FirstName LastNameAlan Snyder
 Comapany NameaShareX Fine Art, LLC
 March 13, 2024 Page 2
 FirstName LastName
Alan Snyder
aShareX Fine Art, LLC
March 13, 2024
Page 2
directly or indirectly on transactions in securities."
            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 Scott Anderegg at 202-551-3342 or Donald Field at 202-551-3680 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services