SEC Company Response from REED'S, INC. (REED) (CIK 0001140215) (REED) — Dec 17, 2009
REED'S, INC. (REED) (CIK 0001140215)
Date: Dec. 17, 2009 · CIK: 0001140215 · Accession: 0001019687-09-004595
AI Filing Summary & Sentiment
File numbers found in text: 001-32501
Referenced dates: December 16, 2009
Show Raw Text
CORRESP
1
filename1.htm
reeds_corresp2-121709.htm
Reed’s
Inc.
13000
South Spring Street
Los
Angeles, CA 90061
December
17, 2009
John
Reynolds
United
States Security and Exchange Commission
Division
of Corporate Finance
Office of
Beverages, Apparel and Healthcare Services
100 F
Street, North East
Washington,
D.C. 20549-3561
RE:
Reed’s
Inc.
Form
10-K for the fiscal year ended December 31, 2009
Filed
March 27, 2009
Form
10-Q/A for fiscal quarter ended September 30, 2009
Filed
December 7, 2009
File
No 001-32501
Dear Mr.
Reynolds:
We are in
receipt of your letter dated December 16, 2009. Below are your
comments with our response:
Form 10-Q/A for fiscal
quarter ended September 30, 2009
Exhibits
1.
You
appear to have omitted the base copacking fee information from Exhibit B
to the Brewing Agreement with The Lion Brewery dated November 1, 2008,
refilled as exhibit 10.2 to your Form 10-Q/A filed December 7,
2009. Please refile the agreement in its entirety, including
the currently omitted portions. To the extent you wish to obtain
confidential treatment of information contained in a document filed under
the Exchange Act of 1934, you must follow the procedures contained in Rule
24b under the Exchange Act. Please note that you must indicate at the
appropriate place within the publicly filed document that any confidential
portion has been omitted and filed separately with the
Commission.
Response
We have
refilled the exhibits with our amended Form 10Q/A, Amendment 2, for the fiscal
quarter ended September 30, 2009 as Exhibit 10.1, Brewing Agreement between
Reed’s Inc. and the Lion Brewery, Inc. dated November 1,
2008. Portions of the exhibit have been omitted pursuant to a request
for confidential treatment. The redacted information has been marked
to indicate that the confidential treatment has been requested and that the
material has been filed separately.
We have
filed an Application for Confidential Treatment of the redacted information
pending the SEC's review of the confidential treatment request. We have
separately delivered the confidential information to the Secretary, Securities
Exchange Commission.
Sincerely,
/s/ James
Linesch
James
Linesch
Chief
Financial Officer
Reed’s
Inc.