January 13, 2023


Via U.S. Mail

James O   Neill Simpson
410-Nrace
Van Wert, Ohio 45891


                      Re:     James O   Neill Simpson LLC
                              File No. 811-23605

Dear James O   Neil Simpson:

        On September 2, 2020 you filed a Form N-8A notifying the Commission of
your
intention to register as an investment company under the Investment Company Act
of 1940
(   1940 Act   ). In that filing, you note that you are concurrently filing a
registration statement
pursuant to Section 8(b) of the 1940 Act but the registration statement was not
included with the
filing nor was it later filed.

        As such, your current filing is materially deficient. Consequently, we
believe you should
either deregister the company or amend the filing to provide substantive and
accurate responses
to the Form N-8A item requirements. In that regard, we believe you should
consult with a
lawyer to assist you with the deregistration process or in complying with the
requirements of
Form N-8A.

       As a result of these deficiencies, you should not deem yourself a
registered    investment
company. We do not believe investors should rely on the documents you have
filed with us for
any investment purpose. It is our intention to post this letter.

If you have any questions, you may contact our office at (202) 551-6921.

                                                 Sincerely,


                                                 Disclosure Review and
Accounting Office