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                          November 2, 2021

       Eric Miller
       General Counsel
       Vintage Wine Estates, Inc.
       937 Tahoe Boulevard, Suite 210
       Incline Village, Nevada 89451

                                                        Re: Vintage Wine
Estates, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed October 27,
2021
                                                            File No. 333-260530

       Dear Mr. Miller:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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 Gregory
Herbers at 202-551-8028 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Manufacturing
       cc:                                              Joel May