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CORRESP
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filename1.htm

February
6, 2026

VIA
ELECTRONIC EDGAR FILING

Office
of Trade & Services

Division
of Corporation Finance

Securities
and Exchange Commission

100
F. Street, N.E.

Washington,
D.C. 20549

    Re:
    Masterworks
    Vault 10, LLC

    Amendment
    No. 11 to Offering Statement on Form 1-A

    Filed
    January 16, 2026

    File
    No. 024-12323

Dear
Sir or Madam:

We
have electronically filed herewith on behalf of Masterworks Vault 10, LLC (the “Company”) Amendment No. 12 (“Amendment
No. 12”) to the above-referenced offering statement on Form 1-A originally filed on August 23, 2023, as amended (together, the
“Form 1-A”). Amendment No. 12 is marked with < R > tags to show changes made from the Form 1-A filing. In addition,
we have included a narrative response keyed to the comments of the staff of the Division of Corporation Finance (the “Staff”)
set forth in the Staff’s comment letter to Joshua B. Goldstein dated January 30, 2026. We trust you shall deem the contents of
this transmittal letter responsive to your comment letter.

Amendment
No. 11 to Offering Statement on Form 1-A

Series
Offering Table, page 1

    1.
    Comment:
                                            Please explain why the share columns in the table do not reconcile to the adjusted total
                                            shares outstanding column or revise.

    Response: In response to the Staff’s comment,
    the Company would clarify that the Management Fee Shares (Issuer) column of the Series Offering Table (the “Table”) did
    not include any Management Fee Shares originally issued to the Administrator which have been sold or transferred as of the date
    hereof, which is why the share columns in the Table did not reconcile to the adjusted total shares outstanding column. The Company
    has revised the Table and corresponding disclosure through Amendment No. 12 to include such shares. The Company has also added
    additional disclosure relating to beneficial ownership by Masterworks in the sections of Amendment No. 12 entitled
    “Restructuring Transactions - Capital Structure Following the Offering” and “Security Ownership of Management and
    Certain Security Holders.”

Unaudited
Historical and Pro Forma Financial Statements, page F-2

    2.
    Comment:
                                            We note your response to prior comment 2 that updated historical interim financial statements
                                            and pro forma financial statements were included. We were not able to locate historical
                                            interim statements of operations for the registrant, target issuers or pro forma for the
                                            period ended June 30, 2025. Please explain or revise.

    Response:
    The Company has included the requested financial statements in Amendment No. 12.

If
the Staff has any further comments regarding the offering statement on Form 1-A, or any subsequent amendments to the Company’s
offering statement on Form 1-A, please feel free to contact the undersigned.

    MASTERWORKS
    VAULT 10, LLC

    By:

    /s/
    Joshua B. Goldstein

    Joshua
    B. Goldstein

    General
    Counsel and Secretary

    cc:
    Donald
    Field/U.S. Securities and Exchange Commission

    Alyssa
    Wall/U.S. Securities and Exchange Commission

    Scott
    Stringer/U.S. Securities and Exchange Commission

     Adam
    Phippen/U.S.  Securities and Exchange Commission