United States securities and exchange commission logo

                             August 12, 2020

       Stephen J. Barnard
       President and Chief Executive Officer
       Mission Produce, Inc.
       2500 E. Vineyard Avenue
       Suite 300
       Oxnard, CA 93036

                                                        Re: Mission Produce,
                                                            Amendment No. 3 to
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted August 3,
                                                            CIK No. 1802974

       Dear Mr. Barnard:

             We have reviewed your amended draft registration statement and
have the following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

               Please respond to this letter by providing any requested
information and by publicly
       filing your registration statement and non-public draft submission on
EDGAR. If you do not
       believe our comments apply to your facts and circumstances or do not
believe an amendment is
       appropriate, please tell us why in your response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       DRS/A filed August 3, 2020

       Legal Proceedings, page 68

   1.                                                   We note your revised
disclosure that you have been named as a defendant in a civil
                                                        complaint that has been
filed which asserts that you violated certain wage and labor laws
                                                        in California. If
material, please provide all of the information required by Item 103 of
                                                        Regulation S-K.
 Stephen J. Barnard
Mission Produce, Inc.
August 12, 2020
Page 2
Unaudited Condensed Consolidated Financial Statements as of and for the Six
Months Ended
April 30, 2020
Note 5. Equity Method Investees, Moruga Impairment, page F-8

2.       We see that you determined the fair value of Moruga, Inc. using a
combination of the
         market approach and the income approach. Please revise to provide all
of the disclosures
         required by ASC 820-10-50-2 for non-recurring fair value measurements.
In that regard,
         you should consider disclosing how you weighted the market and income
approaches, the
         significant inputs used in the fair value measurement under both
approaches, and
         quantitative information about any significant unobservable inputs
used in the fair value
        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.

        We also remind you that your registration statement must be on file no
later than 48 hours
prior to the requested effective date and time. Refer to Rules 460 and 461
regarding requests for
acceleration. Please allow adequate time for us to review any amendment prior
to the requested
effective date of the registration statement.

        You may contact Kristin Lochhead at (202) 551-3664 or Lisa Vanjoske at
(202) 551-
3614 if you have questions regarding comments on the financial statements and
matters. Please contact Eric Envall at (202) 551-3234 or Sandra Hunter
Berkheimer at (202)
551-3758 with any other questions.

FirstName LastNameStephen J. Barnard                         Sincerely,
Comapany NameMission Produce, Inc.
                                                             Division of
Corporation Finance
August 12, 2020 Page 2                                       Office of Life
FirstName LastName