SecProbe.io

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                          CAPITAL BEVERAGE CORPORATION
                              700 Columbia Street,
                           Erie Basin, Building # 302
                            Brooklyn, New York 11231

                                                              July 11, 2005

Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C. 20549
Mail Stop 0308
Attn:  Mr. Michael Moran

         RE:      Capital Beverage Corporation (the "Company")
                  Form 10-K for the Year Ended December 31, 2004 filed April 15,
                  2005 (the "Recent Annual Report")
                  Form 10-Q for the Quarter Ended March 31, 2005 filed May 23,
                  2005 (the "Recent Quarterly Report")
                  File No. 1-13181

Dear Mr. Mochan:

In connection  with the Staff's  review of the Company's  Recent Annual  Report
and Recent  Quarterly  Report,  set forth below are the Company's responses to
your comments in the order set forth in your letter dated June 17, 2005.

Item 7-Management's Discussion and Analysis

1. The Company takes the staff's comment under advisement and will provide a
table of contractual obligations in future filings.

Item 7A-Quantitiave and Qualitative Disclosures about Market Risk

2. The Company takes the staff's comment under advisement and will provide
narrative  disclosure  concerning the interest rate risk to the Company in
future filings.

<PAGE>

Mr. Michael Moran
July 11, 2005
Page 2

Item 9A-Controls and Procedures

3. The Company takes the staff's comment under advisement and will indicate that
the Company's executives evaluated the controls and procedures as of the end of
the period presented in future filings.

Report of Independent Accountant

4. The Company takes the staff's comment under advisement and will present its
accountant's report that applies to all periods presented in future filings.

Balance Sheet

5. The Company takes the staff's comment under advisement and will disclose the
allowance for doubtful accounts on the face of the income statement or in the
notes to the financial statements as well include the schedules required by Rule
5-04 of Regulation S-X in future filings.

Please be advised that the Company acknowledges that:

     o    It is responsible  for the adequacy and accuracy of the disclosures in
          its filings;
     o    Staff's  comments  or  changes  to  disclosure  in  response  to staff
          comments do not  foreclose  the  Securities  and  Exchange  Commission
          ("Commission") from taking any action with respect to its filings; and
     o    It may not assert this action as a defense in any proceeding initiated
          by the Commission or any person under the federal  securities  laws of
          the United States.

          Thank you for your cooperation.

                                                   Very truly yours,

                                                   /s/ Carmine Stella
                                                   -----------------------------
                                                   Carmine Stella
                                                   President and Chief Executive
                                                   Officer

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