United States securities and exchange commission logo June 16, 2020 Harold S. Edwards President and Chief Executive Officer Limoneira Company 1141 Cummings Road Santa Paula, California 93060 Re: Limoneira Company Registration Statement on Form S-3 Filed June 10, 2020 File No. 333-239061 Dear Mr. Edwards: 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 Tim Buchmiller at (202) 551-3635 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Stephen C. Mahon, Esq.