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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

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Document Type
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Summary

Reasoning

File numbers found in text: 001-32501

Referenced dates: December 16, 2009

Date
December 31, 2009
Author
/s/ James
Form
CORRESP
Company
REED'S, INC. (REED) (CIK 0001140215)

Letter

United States Security and Exchange Commission Division of Corporate Finance Office of Beverages, Apparel and Healthcare Services 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

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.