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April 28, 2023
Khachatur Mkrtchyan
Chief Executive Officer
LEGEND SPICES, INC.
14 Kajaznuni Street, Apt. 70
Yerevan 0070 Armenia
Re:LEGEND SPICES, INC.
Registration Statement on Form S-1
Filed April 10, 2023
File No. 333-271201
Dear Khachatur Mkrtchyan:
            We have reviewed your registration statement 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 registration 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 registration statement and the information you
provide in response to these comments, we may have additional comments.

 FirstName LastNameKhachatur Mkrtchyan
 Comapany NameLEGEND SPICES, INC.
 April 28, 2023 Page 2
 FirstName LastName
Khachatur Mkrtchyan
LEGEND SPICES, INC.
April 28, 2023
Page 2
Registration Statement on Form S-1 Submitted April 10, 2023
Cover Page
1.Please revise the first paragraph to specify the date when this best-efforts offering will
end. Refer to Item 501(b)(8) of Regulation S-K.
Risk Factors
Our business is subject to risks associated with sourcing and manufacturing in Armenia., page 12
2.We note that you rely on a suppliers located solely in Armenia. Please disclose the risks of
this reliance and any disruptions you have experienced due to such reliance. We note your
risk factor that your supply chain may be impacted by recent turmoil related to the Second
Nagorno-Karabakh War. Update your risks characterized as potential if recent supply
chain disruptions have impacted your operations.
Because our business is highly concentrated on a single, discretionary product category, food
seasonings, we are vulnerable to changes in co, page 13
3.We note your risk factor indicating that inflation could affect consumer purchases of
discretionary items. Please update both this risk factor and your Management's Discussion
and Analysis if recent inflationary pressures have materially impacted your operations. In
this regard, please identify the types of inflationary pressures you are facing and how your
business has been affected.
Critical Accounting Policies
Revenue Recognition, page 49
4.We note your revenue recognition policy disclosed on pages 49 and F-7; however, we do
not consider the information sufficient in meeting the disclosure objective of the ASC
606-10-50. The objective of the disclosure requirements is for an entity to disclose
sufficient information to enable users of financial statements to understand the nature,
amount, timing, and uncertainty of revenue and cash flows arising from your contracts
with customers. Consideration should be given to the level of detail necessary to satisfy
the disclosure objective. In this regard, the information should be specific to the company
and avoid the use of boilerplate language. Please revise as necessary.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

 FirstName LastNameKhachatur Mkrtchyan
 Comapany NameLEGEND SPICES, INC.
 April 28, 2023 Page 3
 FirstName LastName
Khachatur Mkrtchyan
LEGEND SPICES, INC.
April 28, 2023
Page 3
            You may 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 Sarah Sidwell at 202-551-4733 or Jay Ingram at 202-551-3397 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Bill Macdonald