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                         July 28, 2020

       Matt Thelen
       General Counsel
       Winc, Inc.
       5340 Alla Road, Suite 105
       Los Angeles, CA 90066

                                                        Re: Winc, Inc.
                                                            Offering Statement
on Form 1-A
                                                            Filed July 10, 2020
                                                            File No. 024-11266

       Dear Mr. Thelen:

                                                        We have reviewed your
offering statement and do not have any comments.

               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. We also remind you that, following qualification of
your Form 1-A, Rule 257
       of Regulation A requires you to file periodic and current reports,
including a Form 1-K which
       will be due within 120 calendar days after the end of the fiscal year
covered by the report.

              Please contact Daniel Morris at (202) 551-3314 or Erin Jaskot at
(202) 551-3442 with
       any other questions.




                         Sincerely,


                         Division of Corporation Finance

                         Office of Trade & Services
       cc:                                              Jeanne Campanelli, Esq.