United States securities and exchange commission logo





                             September 25, 2020

       Frank Igwealor
       Chief Executive Officer
       Video River Networks, Inc.
       370 Amapola Ave., Suite 200A
       Torrance, CA 90501

                                                        Re: Video River
Networks, Inc.
                                                            Amendment No. 2 to
Form 10-12G
                                                            Filed September 10,
2020
                                                            File No. 000-30786

       Dear Mr. Igwealor:

              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 and any amendment you may file in
response to these
       comments, we may have additional comments.

       Amendment No. 2 to Form 10-12G filed September 10, 2020

       Properties, page 52

   1.                                                   Please revise to
indicate approximately how much the company spent on the rehabilitation
                                                        and improvement of the
property at 831 E 94th Street prior to its sale in February 2020.
       Certain Relationships and Related Transactions, and Director
Independence, page 59

   2.                                                   Please revise to
indicate the dates and amounts received from each of the two property
                                                        sales. Also revise to
indicate the amount of the loan from Los Angeles Community
                                                        Capital paid off with
each property sale. Indicate the amount of developer fee paid to Los
                                                        Angeles Community
Capital and Mr. Igwealor from each property sale. Finally, indicate
                                                        the amount of
ownership/control Mr. Frank Igwealor has in Los Angeles Community
                                                        Capital.
 Frank Igwealor
Video River Networks, Inc.
September 25, 2020
Page 2
Report of Independent Registered Public Accounting Firm, page 67

3.       We note the audit opinion was revised to change the date of the
opinion and to include the
         audit of the financial statements for the year ending December 31,
2018. Please have your
         independent auditors further revise their audit opinion to include an
explanatory paragraph
         related to the correction of the material misstatement in previously
issued financial
         statements for the year ended December 31, 2019. Reference is made to
paragraphs 16
         and 17 of PCAOB Auditing Standards 2820 and paragraph 18(e) of PCAOB
Auditing
         Standards 3101.
Note 3. Real Estate Investments, page 76

4.       Within your response to comment 4, you indicate your disclosure has
been revised and
         updated in this section. However, it does not appear that your
disclosure has been revised
         to discuss the correction of an error in previously issued financial
statements. Please
         revise to include the disclosures outlined in paragraphs 250-10-50-7
to 10 of the ASC.
          Such disclosures should be included within your registration
statement as well as your
         amended 10-K annual report and 10-Q periodic report.
5.       We note your responses to comments 5 and 6. We will review the amended
10-K and 10-
         Q when filed and may have additional comments at that time.
General

6.       We note your response to comment 9. As previously requested, please
revise your
         Management's Discussion and Analysis to address the interim periods
for which financial
         information is required and specifically address these periods in the
results of operations,
         real estate properties owned, and the liquidity and capital resources
sections.

        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 Isaac Esquivel at 202-551-3395 or Wilson Lee at
202-551-3468 if you
have questions regarding comments on the financial statements and related
matters. Please
contact David Link at 202-551-3356 or Pamela Long at 202-551-3765 with any
other questions.



FirstName LastNameFrank Igwealor                               Sincerely,
Comapany NameVideo River Networks, Inc.
                                                               Division of
Corporation Finance
September 25, 2020 Page 2                                      Office of Real
Estate & Construction
FirstName LastName