February
7, 2020
VIA EDGAR
Securities
and Exchange Commission
Division
of Corporate Finance
100 F
Street, N.E.
Washington,
DC 20549
Attention:
Sherry Haywood
Re:
Willamette Valley
Vineyards, Inc.
Registration
Statement on Form S-3
File
No.: 333-236080
Request
for Acceleration
Ladies
and Gentlemen:
Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as
amended, the undersigned registrant, Willamette Valley Vineyards,
Inc., an Oregon corporation (the “Registrant”), hereby
requests that the above-referenced Registration Statement (as
amended) be declared effective at 5:30 p.m., Eastern Time, on
February 11, 2020, or as soon as practicable
thereafter.
The
Registrant hereby acknowledges that:
(i)
should the
Securities and Exchange Commission (the “Commission”)
or the staff, acting pursuant to delegated authority, declare the
Registration Statement effective, it does not foreclose the
Commission from taking any action with respect to the Registration
Statement;
(ii)
the action of the
Commission or the staff, acting pursuant to delegated authority, in
declaring the Registration Statement effective, does not relieve
the Registrant from its full responsibility for the adequacy and
accuracy of the disclosure in the Registration Statement;
and
(iii)
the Registrant may
not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United
States.
Yours
truly,
WILLAMETTE VALLEY VINEYARDS, INC.
/s/ James W.
Bernau
James
W. Bernau
President
and Chief Executive Officer