July 30, 2019


N. Nora Nye
Seed Equity Properties LLC
1660 South Albion Street
Suite 321
Denver, Colorado 80222

       Re:      Seed Equity Properties LLC
                Amendment No. 2 to
                Offering Statement on Form 1-A
                Filed July 23, 2019
                File No. 024-11048

Dear Ms. Nye:

       We have reviewed your offering statement 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 this letter by amending your offering statement and
providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.

General

   1. We note that you have submitted a legality opinion and copies of
non-public
      correspondence related to your draft offering statement as correspondence
on EDGAR.
      Please note that Form 1-A requires you to submit these documents as
exhibits to the filing
      and revise accordingly. Refer to Items 17(12) and (15)(b) of Part III of
Form 1-A for
      additional guidance. In addition, we note that you have filed three Forms
1-A, each with
      a different file number, however, the two filings submitted on July 23,
2019 appear to be
      amendments to the Form 1-A filed on May 20, 2019 under file number
024-11003.
      Please revise and ensure that all future amendments include the
appropriate file number
      associated with the offering or advise.

        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
 N. Nora Nye
Seed Equity Properties LLC
July 30, 2019
Page 2

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 me at (202) 551-3391 with any questions.


                                                           Sincerely,

                                                           /s/ Erin E. Martin

                                                           Erin E. Martin
                                                           Legal Branch Chief
                                                           Office of Real
Estate and
                                                           Commodities