December 19, 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 November 6, 2024 response to our comment letter
and have
the following comment.

       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 October
17, 2024 letter.

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

1.     We have considered your response to comment 2 in our letter dated
October 17,
       2024. Given the quantitative significance of the error and that we do
not agree that
       the factors cited in your qualitative assessment overcome such
significance, we
       disagree with your conclusion that the error was immaterial.
Accordingly, we have
       concluded that your consolidated financial statements for the year ended
December
       31, 2023 are materially misstated and, therefore, should be restated.
Also, in light of
       the restatement, please reassess your conclusions regarding disclosure
controls and
       procedures and internal control over financial reporting for the
impacted periods.
        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.
 December 19, 2024
Page 2



                    Sincerely,

                    Division of Corporation Finance
                    Office of Real Estate & Construction