United States securities and exchange commission logo





                             December 5, 2022

       Robert McKinney
       Chief Legal Officer
       Westrock Coffee Company
       100 River Bluff Drive, Suite 100
       Little Rock, Arkansas 72202

                                                        Re: Westrock Coffee
Company
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed November 18,
2022
                                                            File No. 333-267509

       Dear Robert McKinney:

             We have reviewed your amended 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.
Unless we note
       otherwise, our references to prior comments are to comments in our
October 13, 2022 letter.

       Amendment No. 1 to Registration Statement on Form S-1 filed November 21,
2022

       General

   1.                                                   We note from your
response to prior comment 1 that you are registering the resale of your
                                                        Series A preferred
shares and the resale of the common shares issuable upon conversion
                                                        of your Series A
preferred shares:

                                                              It appears that
there is no market on which your Series A preferred shares are quoted
                                                            or traded.
Therefore, revise to disclose the fixed price at which the preferred shares
                                                            will be resold for
the duration of the resale offering; and
                                                              If you are
registering the resale of the preferred shares, please also register the
                                                            primary offering by
you of the underlying shares of common stock to subsequent
 Robert McKinney
Westrock Coffee Company
December 5, 2022
Page 2
          purchasers of the preferred shares. Ensure your fee table and
legality opinion are also
          revised to reflect this additional transaction.

       You may contact Alex King at 202-551-8631 or Geoffrey Kruczek at
202-551-3641 with
any questions.



                                                           Sincerely,
FirstName LastNameRobert McKinney
                                                           Division of
Corporation Finance
Comapany NameWestrock Coffee Company
                                                           Office of
Manufacturing
December 5, 2022 Page 2
cc:       Brandon Price
FirstName LastName