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                             July 19, 2021

       Gerome Daren Sapp
       Chief Executive Officer
       370 Markets LLC
       8545 W. Warm Springs Road, Ste A4 #192
       Las Vegas, NV 89113

                                                        Re: 370 Markets LLC
                                                            Offering Statement
on Form 1-A
                                                            Post-qualification
Amendment No. 2
                                                            Filed July 12, 2021
                                                            File No. 024-11383

       Dear Mr. Sapp:

             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. 2 to Offering Statement on Form 1-A

       General

   1.                                                   We note your response
to comment 1, and your amended financial statements. Please
                                                        amend to provide an
updated auditor consent. Refer to part 11 of Item 17 of Form 1-A.
                                                        As a related matter, it
appears that there has been a change in your certifying accountant,
                                                        but you did not file a
1-U reporting this change. Therefore, please amend your disclosure
                                                        to provide the
information required by Item 4 of Form 1-U and, pursuant to part 9 of Item
                                                        17, please file a
letter from your former independent accountant regarding its concurrence
                                                        or disagreement with
any disclosure you provide related to the dismissal or resignation of
                                                        your former accountant.
For guidance, see Rule 252 of Regulation A, which requires
                                                        disclosure of material
information necessary to make the required statements, in light of
                                                        the circumstances under
which they are made, not misleading.
 Gerome Daren Sapp
FirstName  LastNameGerome Daren Sapp
370 Markets  LLC
Comapany
July       Name370 Markets LLC
     19, 2021
July 19,
Page  2 2021 Page 2
FirstName LastName
        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.

       Please contact Katherine Bagley at (202) 551-2545 or Erin Jaskot at
(202) 551-3442 with
any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Trade &
Services