COVER 9 filename9.txt chris@threshold.cc 804.510.0638 December 18, 2020 VIA EMAIL to wirthc@sec.gov Cara Wirth Division of Corporation Finance Office of Trade & Services Securities and Exchange Commission Washington, D.C. 20549 Re: VV Markets LLC; Offering Statement on Form 1-A, File No. 024-11306 Dear Ms. Wirth: This letter responds to your letter of November 23, 2020, for which we thank you. We are requesting qualification of the offering statement of VV Markets LLC (the "Company"). The Company has updated its offering circular under Form 1-A in response to the November 23 letter. We have re-filed the Form 1-A along with this letter and other exhibits. The new or updated exhibits include: * Subscription Agreement for investors * Invoices for Manager's purchase of assets * Purchase and Sale Agreement for purchase of assets by the issuer * North Capital Information Technology agreement (i.e., technical platform, escrow) * Social media posts consisting of testing the waters materials Here are a few notes for certain questions in the November 23 letter. For all other comments, the necessary changes in response to the comments have been made inside the amended offering circular that is submitted with this letter. Comment 4(a): We have updated the Form 1-A and the offering circular to reflect the current state of affairs - the issuer has not yet purchased and does not currently hold any assets, but will purchase the identified assets from the manager upon qualification and raising sufficient funds to do so. Comment 4(a): The operating agreement reference to the state and federal courts in Richmond, Virginia is intentional, in recognition of the fact that there are both state and federal courthouses in Richmond. Depending upon the circumstances, potential claim amounts, and their own place of residence, members might have better jurisdictional bases in state courts or in federal courts. The referenced provisions of the operating agreement allow for dispute resolution in either forum. Comment 7: We have updated the offering circular in the Description of Series Asset section and the Asset Acquisition by Manager and by Series section, to more clearly and completely state the facts requested. The invoices showing the acquisition of the assets by the Manager are attached as an exhibit. Form 1-A has also been updated accordingly. The Use of Proceeds section of the offering circular has also been updated to add the difference precise cost of asset acquisition by the manager, $40,961.48, and the price to be paid by the issuer, $42,000.00, as part of the sourcing fee and expense reimbursement that will be paid to the manager. Comment 8: The subscription agreement, Exhibit 4.1, is submitted with this filing. Comment 9: The website has been updated as well, to remove the reference to "as low as $25." The new public-facing website can be seen at http://vint.co. Comment 10: The requested social media messages and the website referenced above are the extent of the testing the waters messaging. Screenshots of those messages from Twitter are submitted with this filing. The current Twitter account content can be seen at https://twitter.com/investvint We trust that this letter, together with the accompanying documents, will satisfy the comments and remaining requirements, and we therefore request qualification of the Company's offering. Very truly yours, /s/ Christopher E. Gatewood Christopher E. Gatewood Threshold Counsel, PC cc: Nicholas King, VV Markets LLC