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                             October 20, 2021

       Tim Michaels
       Chief Operating Officer
       Fresh Grapes, LLC
       505 Highway 169 North
       Plymouth, MN 55441

                                                        Re: Fresh Grapes, LLC
                                                            Draft Registration
Statement on Form S-1
                                                            Filed September 27,
2021
                                                            File No. 377-05537

       Dear Mr. Michaels:

              We have reviewed your draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Draft Registration Statement on Form S-1, filed September 27, 2021

       General

   1.                                                   Please include a
discussion on the principal sources and locations of your grape suppliers,
                                                        the names of your grape
suppliers, and what impact the locations of your sources of
                                                        grapes may have on the
ability of the company to market its wines as Napa wines and the
                                                        ability to use
specified appellations on the company   s wines. Please refer to Item 101(h)
                                                        of Regulation S-K.
       Prospectus Summary, page 1

   2.                                                   Please revise to ensure
that the information you provide in your summary is balanced. For
                                                        example, we note your
disclosure elsewhere of Fresh Grapes    related party payables,
 Tim Michaels
FirstName LastNameTim  Michaels
Fresh Grapes, LLC
Comapany
October 20,NameFresh
            2021     Grapes, LLC
October
Page 2 20, 2021 Page 2
FirstName LastName
         limited operating history, and history of net losses. To the extent
that you cite strengths in
         your summary, please review each one and revise as necessary to
provide balanced
         information, rather than merely listing generalized risk factors at
the end of this section.
Implications of Being an Emerging Growth Company, page 6

3.       We note your disclosure on page seven which indicates you have elected
to use the
         extended transition period for complying with new or revised
accounting standards that
         have different effective dates for public and private companies. We
note elsewhere in
         Note 1 of your financial statements under, "Application of New or
Revised Accounting
         Standards", that you have irrevocably elected not to take advantage of
the extended
         transition period afforded under the JOBS Act for the implementation
of new or revised
         accounting standards. Please clarify and consistently disclose the
position you are taking
         on the extended transition period afforded under the JOBS Act.
Summary of Historical Financial Data, page 10

4.       We note in the presentation of your Summary Historical Financial Data
that you present
         your 2020 and most recent interim period data in the columns on the
right and prior
         periods in the column on the left. We note elsewhere in your financial
statements that the
         presentation is reversed. Please modify your presentation of period
data to consistently
         present information in the same left-to-right chronological order to
avoid investor
         confusion. You may refer to SAB Topic 11:E for guidance.
Use of Proceeds, page 34

5.       Please file as an exhibit to this registration statement any
agreements with Damian Novak
         that include the advanced funds discussed in this section and the
subsequent
         reimbursement to be paid by the proceeds of this offering. Please
refer to Item
         601(b)(10)(ii)(A) of Regulation S-K.
Revenue Channels, page 43

6.       We note your disclosure that direct to consumer sales channels offer
"significantly" higher
         margins than other sales channels. Please provide such additional
disclosure necessary to
         support this conclusion.
Production and Bottling on an Alternating Proprietorship Basis , page 50

7.       Please revise to include all material terms of the agreements in place
with the host winery.
         Please also file these agreements as exhibits to this registration
statement. Please refer
         to Item 601(b)(10)(ii)(B) of Regulation S-K.
Certain Relationships and Related Party Transactions, page 65

8.       It is not clear whether the agreement with Nechio & Novak is the same
agreement that
         you have with Rabbit Hole Equity. There appear to be some
discrepancies and/or
 Tim Michaels
Fresh Grapes, LLC
October 20, 2021
Page 3
         ambiguity throughout the prospectus relating to terms of the
agreement(s), such as: (i)
         which entity, Nechio & Novak MGT or Rabbit Hole Equity, is party to
the agreement
         involving the "4% of revenue" fee and (ii) whether the "4% of revenue"
fee arrangement
         terminates upon completion of this offering or is subject to the
ten-year initial term. Refer
         to the disclosure on page 65 and Notes 8 and 10 to the financial
statements. Please advise.
Consulting Agreement with Tribe of Five, LLC, page 68

9.       Please discuss the material terms of the consulting agreement with
Tribe of Five, LLC and
         file the agreement as an exhibit to the registration statement. Please
refer to Item
         601(b)(10)(ii)(A) of Regulation S-K.
Financial Statements
Note 7. Supplier Concentration, page F-12

10.      We note your disclosure which states the Company purchases finished
goods through
         blanket sales orders and that your inventory balance appears to only
contain finished
         goods inventories and related deposits. We note elsewhere in your
business section that
         you characterize your company as a "producer" and that you "craft and
bottle" your
         wines. Please explain to us your obligations associated with grape and
juice inventories
         as well as unfinished wines that appear to be produced on your behalf.
It is unclear
         whether or not the company is obligated to procure raw materials;
whether it has
         obligations associated with unfinished product and whether the company
is obligated to
         purchase all finished products, regardless of quality or yield. To the
extent you do not
         have inventory risk and obligations associated with wine production,
it is unclear why you
         are characterizing your company as a "producer." It is further unclear
why wines you say
         are produced under contractual arrangements under your direction and
on your behalf,
         also require you to pay a 50% deposit for the finished goods. Please
more clearly
         disclosure the nature and obligations associated with your contractual
arrangements and
         why you believe you are a wine producer.
       You may contact Kevin Stertzel at (202)-551-3723 or John Cash at
(202)-551-3768 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Bradley Ecker at (202)-551-4985 or Jay Ingram at (202)-551-3397 with
any other
questions.



FirstName LastNameTim Michaels                                 Sincerely,
Comapany NameFresh Grapes, LLC
                                                               Division of
Corporation Finance
October 20, 2021 Page 3                                        Office of
Manufacturing
FirstName LastName