July 3, 2019

Randy S. Gordon
President and Chief Executive Officer
Paradise Inc.
1200 W. Dr. Martin Luther King, Jr. Blvd.
Plant City, FL 33563

       Re: Paradise Inc.
           Revised Preliminary Proxy Statement on Schedule 14A
           Filed June 25, 2019
           File No. 000-03026

Dear Mr. Gordon:

       We have reviewed your filing 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 these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
June 14, 2019 letter.

Revised Preliminary Proxy Statement on Schedule 14A filed June 25, 2019

Annex F
Unaudited Pro Forma Condensed Consolidated Financial Information, page F-1

1.    We have read your response to the third point of prior comment 1,
regarding the pro forma
      Statements of Operations. We had explained that pro forma adjustments for
the
      Liquidation should reflect the accounting that will apply under FASB ASC
205-30, while
      locating buyers for the remaining assets, rather than the sale of the
remaining assets,
      unless and only to the extent that you have secured agreements to sell
the assets and
      thereby meet the factually supportable criteria in Rule 11-02(b)(6) of
Regulation S-X.
      However, you have included adjustments to eliminate all activity
associated with the
      Molded Plastics business and other assets remaining after the sale of the
Fruit Business,
      but have not provided any disclosures indicating buyers for the remaining
assets have
 Randy S. Gordon
Paradise Inc.
July 3, 2019
Page 2
         been found. Please clarify the basis for the adjustments referenced in
pro forma note (4).
2.       Please also adhere to the guidance in Instruction 3 to paragraph (b)
of Rule 11-02(b) of
         Regulation S-X, as requested in the third point of prior comment 1, as
it relates to pro
         forma note (6) and the adjustments that would pertain to selling,
general and
         administrative expenses, and other costs incurred on behalf of the
Fruit Business to be
         divested.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

        You may contact Joseph Klinko, Staff Accountant, at 202-551-3824 or
Karl Hiller,
Accounting Branch Chief, at 202-551-3686 if you have questions regarding
comments on the
financial statements and related matters. Please contact Irene
Barberena-Meissner, Staff
Attorney, at 202-551-6548 or Kevin Dougherty, Staff Attorney, at 202-551-3721
with any other
questions.



FirstName LastNameRandy S. Gordon                             Sincerely,
Comapany NameParadise Inc.
                                                              Division of
Corporation Finance
July 3, 2019 Page 2                                           Office of Natural
Resources
FirstName LastName