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                            October 27, 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. 3 to
Form 10-12G
                                                            Filed October 13,
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. 3 to Form 10-12/G filed 10/13/2020

       Results of Operations
       Years ended December 31, 2018 and 2019 and the 6 Month periods ended
June 30, 2019 and
       2020, page 48

   1.                                                   Please revise your
table on page 49 summarizing your results of operations for the twelve
                                                        months ended December
31, 2018 and 2019 and the six month periods (unaudited) ended
                                                        June 30, 2019 and 2020
to reflect the income statement line amounts consistent with the
                                                        amounts reflected in
your respective consolidated statements of operations. Additionally,
                                                        if you plan to provide
percentage amounts along with the financial amounts, please
                                                        recalculate amounts
appropriately.
       Real Estate Properties Owned, page 50

   2.                                                   We note your response
to comment 6. Please revise your Real Estate Properties Owned
 Frank Igwealor
Video River Networks, Inc.
October 27, 2020
Page 2
         discussion, on page 50, to update the discussion through the interim
period ended June 30,
         2020.
Financial Condition, Liquidity and Capital Resources, page 52

3.       We note that financial information in this section, including changes
in cash flows and
         changes in notes payable and stockholders' deficit for the periods
ending June 30, 2020
         and 2019, is not consistent to the financial information as presented
in your financial
         statements for the respective periods. Please revise to ensure
consistent financial
         information throughout your filing.
        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
October 27, 2020 Page 2                                       Office of Real
Estate & Construction
FirstName LastName