October 17, 2024

Wade Kodama
Chief Financial Officer
Maui Land & Pineapple Company, Inc.
500 Office Road
Lahaina, HI 96761

       Re: Maui Land & Pineapple Company, Inc.
           Form 10-K for the year ended December 31, 2023
           Filed March 28, 2024
           File No. 001-06510
Dear Wade Kodama:

       We have reviewed your October 4, 2024 response to our comment letter and
have the
following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our
September 13, 2024 letter.

Form 10-K for the year ended December 31, 2023
Note 5. Investment in Joint Venture, page 32

1.     We note your response to our prior comment and application of the equity
method of
       accounting for the joint venture even though you own 60% in such
venture. Please
       further describe to us how you considered whether you obtained a
controlling
       financial interest in the joint venture and how the Company determined
that
       consolidation would not be required. Please cite the applicable
accounting guidance in
       your response.
2.     Notwithstanding our prior comment, we note your determination that sales
of land
       are considered part of the Company's primary operations and as such
should be
       recognized as revenue consistent with ASC 606. Given that revenue
recognized under
       ASC 606 is specific to the transfers of goods or services to customers
in exchange for
       consideration, please further describe to us how you determined that the
contribution
 October 17, 2024
Page 2

      of the land to the JV is considered a transaction with a customer for
consideration as
      defined in ASC 606-10-20. In addition, given your determination that the
contribution
      of the land is considered a transaction that should be accounted for
under ASC
      606, please tell us how you considered the need to eliminate your portion
of intra-
      entity profits and losses until realized by the JV consistent with the
guidance in ASC
      323-10-35-7 and ASC 323-10-55-27 through 28.
        Please contact Ameen Hamady at 202-551-3891 or Kristina Marrone at
202-551-3429
if you have questions regarding comments on the financial statements and
related matters.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Real Estate
& Construction