United States securities and exchange commission logo April 27, 2021 Michael Behrens Chief Executive Officer My Racehorse CA LLC 250 W. 1st Street, Suite 256 Claremont, CA 91711 Re: My Racehorse CA LLC Offering Statement on Form 1-A Post-Qualification Amendment No. 24 Filed April 20, 2021 File No. 024-10896 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. 24 to Form 1-A Exhibit 12.1 1. It is inappropriate for counsel to assume the due execution and delivery of documents of the Company. Please revise the last sentence on page 1 of the opinion accordingly. 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. Michael Behrens My Racehorse CA LLC April 27, 2021 Page 2 Please contact Cara Wirth at (202) 551-7127 or Lilyanna Peyser at (202) 551-3222 with any other questions. Sincerely, FirstName LastNameMichael Behrens Division of Corporation Finance Comapany NameMy Racehorse CA LLC Office of Trade & Services April 27, 2021 Page 2 cc: Christopher Tinen FirstName LastName