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August 18, 2023
Parker Graham
Chief Executive Officer
Vestible Assets, LLC
5440 West 110th Street, Suite 300
Overland Park, Kansas 66211
Re:Vestible Assets, LLC
Draft Offering Statement on Form 1-A
Submitted July 28, 2023
CIK No. 0001984345
Dear Parker Graham:
            We have reviewed your draft offering 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 providing the requested information and either submitting
an amended draft offering statement or publicly filing your offering statement on
EDGAR.  Please refer to Rule 252(d) regarding the public filing requirements for non-public
submissions, amendments and correspondence.  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 your amended draft offering statement or filed offering
statement and the information you provide in response to these comments, we may have
additional comments.
Draft Offering Statement on Form 1-A submitted July 28, 2023
Risk Factors
"There is no way to guarantee that any individual player will produce sufficient (or any)
professional sports income . . . .", page 15
1.Please provide, here or as a new risk factor, more robust disclosure highlighting that you
will pay 80% of the proceeds from this offering to Browning and receive 1% of his future
gross sports income, as you state on page 39.  As appropriate, address the risk that it may
take a significant amount of time for investors to recover their initial investment due to
such terms.

 FirstName LastNameParker Graham
 Comapany NameVestible Assets, LLC
 August 18, 2023 Page 2
 FirstName LastName
Parker Graham
Vestible Assets, LLC
August 18, 2023
Page 2
Athlete Overview, page 39
2.Please refer to the second paragraph and the disclosure that "the remaining Brand Income
available under Baron’s player contract with the Broncos will be $2,297,620, none of
which is guaranteed. Baron’s contract with the Broncos will expire in 2025."  Please
revise to quantify the amounts that the Series BDBR would be entitled to based upon the
current Brand Agreement over the remaining term of the existing contract.  Consider
adding a chart or some other clear presentation so that investors can clearly understand the
amounts payable to the Series BDBR per year under the Brand Agreement and any
existing player contracts.
General
3.Please provide your analysis as to whether the Brand Agreement with Baron Browning,
including your right to receive 1% of Baron Browning's future gross sports income as a
professional football player in the NFL, are “investment securities” as defined in Section
3(a)(2) of the Investment Company Act.  In your response, please include any relevant
case law, no-action letters or other authorities.
4.We note your disclosure on page 20 that "[t]he Company is not registered and will not be
registered as an investment company under the Investment Company Act of
1940."  Please provide your analysis as to whether Series BDBR may be considered an
“investment company” under the Investment Company Act and, if so, whether any
exemptions or exclusions may be applicable. In your response, please cite to any case law,
no-action letters or other authorities that you believe may be relevant. Please revise your
risk factor entitled "If the Company is required to register under the Investment Company
Act . . . " as appropriate to include a more detailed discussion of such risk and related
analysis.
            Please contact Brian Fetterolf at 202-551-6613 or Donald Field at 202-551-3680 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Dan McAvoy