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SEC Company Response from REED'S, INC. (REED) (CIK 0001140215) (REED) — Nov 3, 2009

REED'S, INC. (REED) (CIK 0001140215)
Date: Nov. 3, 2009 · CIK: 0001140215 · Accession: 0001019687-09-003907

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File numbers found in text: 333-156908

Date
Nov. 3, 2009
Author
/s/ Christopher J. Reed
Form
CORRESP
Company
REED'S, INC. (REED) (CIK 0001140215)

Letter

Office of Beverages, Apparel and Healthcare Services United States Securities and Exchange Commission Division of Corporate Finance Office of Beverages, Apparel and Healthcare Services United States Securities and Exchange Commission Division of Corporate Finance RE: Reed’s Inc. Registration Statement on Form S-3/A, filed October 14, 2009 File No. 333-156908

Dear Mr. Reynolds:

Reed’s Inc. (the “Company”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to make the above-captioned registration statement be ordered effective at 10:00 a.m. (E.S.T.) on Thursday, November 5, 2009, or as soon as practicable thereafter.

The Company acknowledges that:

1.

should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

2.

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

3.

the Company may not assert the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please do not hesitate to contact Ruba Qashu, Qashu & Schoenthaler LLP, by telephone at (949) 355-5405 or by facsimile at (866) 313-3040, should you have any questions.

Sincerely,
/s/ Christopher J. Reed

Show Raw Text
CORRESP
1
filename1.htm

    reeds_corresp-110309.htm

    REED’S,
INC.

    13000
South Spring Street

    Los
Angeles, California 90061

    (310)
217-9400

    November
3, 2009

    John
Reynolds

    Assistant
Director

    Office of
Beverages, Apparel and Healthcare Services

    United
States Securities and Exchange Commission

    Division
of Corporate Finance

    Edwin
Kim

    Staff
Attorney

    Office of
Beverages, Apparel and Healthcare Services

    United
States Securities and Exchange Commission

    Division
of Corporate Finance

            RE:

              Reed’s
      Inc.

              Registration
      Statement on Form S-3/A, filed October 14, 2009

              File
      No. 333-156908

    Dear Mr.
Reynolds:

    Reed’s
Inc. (the “Company”) hereby requests that the Securities and Exchange Commission
(the “Commission”) take appropriate action to make the above-captioned
registration statement be ordered effective at 10:00 a.m. (E.S.T.)
on  Thursday, November 5, 2009, or as soon as practicable
thereafter.

    The
Company acknowledges that:

              1.

              should
      the Commission or the staff, acting pursuant to delegated authority,
      declare the filing effective, it does not foreclose the Commission from
      taking any action with respect to the
filing;

              2.

              the
      action of the Commission or the staff, acting pursuant to delegated
      authority, in declaring the filing effective, does not relieve the Company
      from its full responsibility for the adequacy and accuracy of the
      disclosure in the filing; and

              3.

              the
      Company may not assert the declaration of effectiveness as a defense in
      any proceeding initiated by the Commission or any person under the federal
      securities laws of the United
States.

    Please do
not hesitate to contact Ruba Qashu, Qashu & Schoenthaler LLP, by telephone
at (949) 355-5405 or by facsimile at (866) 313-3040, should you have any
questions.

                Sincerely,

                /s/ Christopher J. Reed

                Christopher
      J. Reed

                Chief
      Executive Officer

                Reed’s,
      Inc.