February 12, 2020

B. John Lindeman
Chief Financial Officer
CALAVO GROWERS INC
1141-A Cummings Road
Santa Paula, CA 93060

       Re: CALAVO GROWERS INC
           Form 10-K for the Fiscal Year Ended October 31, 2019
           Filed December 19, 2019
           Form 8-K Filed December 20, 2019
           File No. 000-33385

Dear Mr. Lindeman:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 8-K filed December 20, 2019

Reconciliation of Adjusted Net Income and EPS, page 9

1.    Please tell us why your adjustment (a) to eliminate the equity pickup for
your investment
      in FreshRealm and adjustment (e) which adds back in the losses recorded
with respect to
      your equity investment in Limoneira do not substitute
individually-tailored income or
      expense recognition methods for those of GAAP. Refer to Question 100.04
of the
      Division's Non-GAAP Financial Measures Compliance and Disclosure
Interpretations.
 B. John Lindeman
FirstName GROWERS INC Lindeman
CALAVO LastNameB. John
Comapany NameCALAVO GROWERS INC
February 12, 2020
Page 2
February 12, 2020 Page 2
FirstName LastName
       In closing, 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.

       You may contact Christine Torney at 202-551-3652 or Mary Mast at
202-551-3613 with
any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Life
Sciences