United States securities and exchange commission logo October 7, 2020 Brittney Rogers Managing Member Emancipation Fund Initiative LLC 5330 Griggs Road #D107 Houston, Texas 77021 Re: Emancipation Fund Initiative LLC Amendment No. 1 to Draft Offering Statement on Form 1-A Filed September 16, 2020 File No. 367-00255 Dear Ms. Rogers: We have reviewed your amended draft offering statement 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 providing the requested information and either submitting an amended draft offering statement or publicly filing your offering statement on EDGAR. 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 draft offering statement or filed offering statement and the information you provide in response to this comment, we may have additional comments. Amendment No. 1 to Draft Offering Statement General 1. We note your response to comment 1 that the renewal of the notes is included in the total offering amount. Please provide your analysis as to why you believe this offering is a continuous offering pursuant to Rule 251(d)(3), rather than a delayed offering, since the renewal notes will not be offered until at the maturity of the initial offering of notes. Brittney Rogers FirstName LastNameBrittney Rogers Emancipation Fund Initiative LLC Comapany October NameEmancipation Fund Initiative LLC 7, 2020 October Page 2 7, 2020 Page 2 FirstName LastName You may contact Howard Efron at 202-551-3439 or Robert Telewicz at 202-551-3438 if you have questions regarding the financial statements and related matters. Please contact Ronald (Ron) Alper at 202-551-3329 or Pam Howell at 202-551-3357 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Samuel E. Whitley