SecProbe.io

March 24, 2025
Joshua Goldstein
General Counsel and Secretary
Masterworks Vault 2, LLC
1 World Trade Center, 57th Floor
New York, New York 10007
Re:Masterworks Vault 2, LLC
Post-Qualification Amendment No. 14 to Offering Statement on Form 1-A
Filed March 12, 2025
File No. 024-12271
Dear Joshua Goldstein:
            We have reviewed your amended offering statement and have the following
comments.
            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. Unless we note
otherwise, any references to prior comments are to comments in our February 27, 2025 letter.
Post-Qualification Amendment No. 14 to Offering Statement on Form 1-A
Risk Factors
Risks Associated with an Investment in the Artwork
Calculation of the Masterworks Artist Market Index involves a degree of subjectivity..., page
16
1.We note your amended disclosure in response to prior comment 1. Please expand your
disclosure regarding the categorization of artwork by "perceived quality" to clarify
what factors comprise the quality score, and whether such qualities reflect objective
features of the artwork or subjective assessments of the value of the artwork. If the
latter, please address the potential risks associated with the subjective assessment of
"artwork quality" by Masterworks employees or agents, including potential conflicts
of interest.

March 24, 2025
Page 2
General
2.We note your response to prior comment 2 regarding the use of artificial intelligence
by the Masterworks internal research team. Please clarify how the machine learning
you use differs from simple algorithmic code that automates the Masterworks internal
research team's processes. In addition, clarify whether the artificial intelligence is a
third-party product or an internally developed artificial intelligence process.
Additionally, please include an appropriate risk factor addressing the material risks to
your business, operations, and financial condition in connection with the use and
development, if applicable, of artificial intelligence in such research processes.
            Please contact Alyssa Wall at 202-551-8106 or Dietrich King at 202-551-8071 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services