January 22, 2020

Julio Macedo
Manager
American Diversified Energy LLC
711 W. 17th Street, Suite D-5
Costa Mesa, CA 92627

       Re: American Diversified Energy LLC
           Amendment Nos. 4 and 5 to Offering Statement on Form 1-A
           Filed January 9 and 14, 2020
           File No. 024-10904

Dear Mr. Macedo:

      We have reviewed your amended 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. Unless
we note
otherwise, our references to prior comments are to comments in our December 2,
2019 letter.

Form 1-A Amendment No. 5 filed January 14, 2020

Results of Operations, page 91

1.    Reference is made to comment 6 and your revised disclosure provided in
the first
      paragraph on page 91. Your disclosure of a net loss for the year ended
October 31, 2018
      and 2017 of $1,214,982 and $307,265 is consistent with the net loss
reported on your
      statements of operations. However, your disclosure of incurred losses of
$682,285 and
      $373,203 for the nine months ended July 31, 2019 and 2018 is not
consistent with the net
      loss reported on your statements of operations. Please revise.
 Julio Macedo
FirstNameDiversified Energy LLC
American LastNameJulio Macedo
Comapany NameAmerican Diversified Energy LLC
January 22, 2020
Page 2
January 22, 2020 Page 2
FirstName LastName
Liquidity and Capital Resources, page 92

2.       In the fifth paragraph you refer to a liability of $957,000 to ADE
Crescent while the
         balance sheet presents a liability of $976,650. Please explain or
revise.
Financial Statements, page F-1

3.       In a note or separate statement, please provide an analysis of the
changes in each caption
         of members' deficit presented in the balance sheet as of July 31,
2019. Reference is made
         to (b)(5), Part F/S of Form 1-A.
Note 10 - Subsequent Events
Investment of Corvette, LLC in ADE Crescent City LLC and Summary of the Amended
Restated Operating Agreement of ADE Crescent City LLC, page F-26

4.       We are reissuing comment 14 in light of the Form 1-A/A filed January
14, 2020. Your
         response to comment 14 states ADE Crescent was in the construction
stage and did not
         exceed the 20% threshold in Rule 8-03(b)(3) of Regulation S-X.
However, subsequent to
         your response, in Form 1-A/A filed January 14, 2020, the balance sheet
presents an equity
         method investment balance of $334,455, which exceeds 20% of your
consolidated assets.
         Please revise to provide the required Rule 8-03(b)(3) of Regulation
S-X disclosure or
         explain why such disclosure is not required.
5.       You disclose that management determined that the receivable recorded
on ADE Crescent
         City books and records of $976,000 is likely not recoverable from the
Company. Please
         disclose the bad debt expense recorded.
       You may contact Scott Stringer at (202) 551-3272 or Adam Phippen at
(202) 551-3336 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Daniel Morris at (202) 551-3314 or Mara Ransom, Office Chief, at (202)
551-3264 with
any other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Trade &
Services
cc:      Kristin Cano, Esq.