United States securities and exchange commission logo





                            September 30, 2022

       Michael Behrens
       Chief Executive Officer
       My Racehorse CA LLC
       120 Kentucky Ave., Suite 110
       Lexington, KY 40502

                                                        Re: My Racehorse CA LLC
                                                            Offering Statement
on Form 1-A
                                                            Post-qualification
Amendment No. 6
                                                            Filed September 16,
2022
                                                            File No. 024-11808

       Dear Mr. Behrens:

             We have reviewed your amendment and have the following comment. In
our comment,
       we may ask you to provide us with information so we may better
understand your disclosure.

              Please respond to this letter by amending your offering statement
and providing the
       requested information. If you do not believe our comment applies to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response. After reviewing any amendment to your offering statement and
the information you
       provide in response to this comment, we may have additional comments.

       Post-qualification Amendment No. 6 to Form 1-A Filed September 16, 2022

       General

   1.                                                   We note that you are
not the majority owner of Ravens Lady 21, Cuvier, and Forever
                                                        Rose, and that you are
not the sole Administrative Coordinator or do not have the sole
                                                        power to appoint the
Administrative Coordinator for such horses. However, we note your
                                                        disclosure on page 17
that "no Series will hold underlying assets in which the Manager
                                                        has limited or no
management control, so that it is not considered to be an investment
                                                        company within the
meaning of the Investment Company Act" and your disclosure on
                                                        page 131 that "[a]s
with Co-Ownership structures, the Company, directly or indirectly, is
                                                        engaged daily on key
operating decisions and has approval rights over a broad range of
                                                        day-to-day operational
matters that directly impact the value of the Lease Agreements for
                                                        such Underlying Asset
of a Series." Please tell us how you intend to maintain control,
                                                        engage in the key
operating decisions, and retain the right to approve day-to-day
                                                        operational matters of
Ravens Lady 21, Forever Rose, and Cuvier when it appears that,
 Michael Behrens
My Racehorse CA LLC
September 30, 2022
Page 2
       contractually, you do not have such authority.
        We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.

        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.

       Please contact Cara Wirth at (202) 551-7127 or Lilyanna Peyser at (202)
551-3222 with
any questions.



                                                             Sincerely,
FirstName LastNameMichael Behrens
                                                             Division of
Corporation Finance
Comapany NameMy Racehorse CA LLC
                                                             Office of Trade &
Services
September 30, 2022 Page 2
cc:       Christopher Tinen
FirstName LastName