SEC Company Response from REED'S, INC. (REED) (CIK 0001140215) (REED) — Nov 19, 2008
REED'S, INC. (REED) (CIK 0001140215)
Date: Nov. 19, 2008 · CIK: 0001140215 · Accession: 0001144204-08-065737
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-146012
Referenced dates: August 21, 2008, November 10, 2008
Letter
REED’S, INC.
SOUTH SPRING STREET
LOS ANGELES, CA 90061
November 19, 2008
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
First Street, N.E.
Washington, D.C. 20249
Attn:
John Reynolds, Assistant Director
Damon Colbert, Staff Attorney
RE:
Reed’s, Inc.
Post-Effective Amendment No. 2 to Registration Statement on Form S-1
Filed on October 31, 2008
File No. 333-146012
Gentlemen:
Set forth below are the Company’s responses to the comments received from the staff (“Staff”) of the Securities and Exchange Commission in the letter dated November 10, 2008. We have reproduced the Staff’s comments for your convenience and have followed the comment with the Company’s response. References in this letter to “we”, “our”, or “us” mean the Company or its advisors, as the context may require. Capitalized terms not defined herein have the meaning set forth in the Registration Statement.
Risk Factors, page 5
1. We note your response to comment one of our letter dated August 21, 2008 and the revised disclosure on page 15. Please revise where appropriate to summarize the status of the remediation efforts described on pages 38 and 39 of your Form 10-KSB filed April 15, 2008. For example, in your Form 10-KSB, you describe remediation efforts for different systems, reviews, procedures, and other items with anticipated completion dates ranging from the second quarter of 2008 to the fourth quarter of 2008. Please revise your registration statement to briefly describe the status of these efforts.
Response: We have revised our registration statement accordingly.
Form 10-KSB/A for Fiscal Year Ended December 31, 2007
Page 1 of 2
Exhibits
2. We note that you changed the term “internal control over financial reporting” to “internal controls” in the certification required by Exchange Act Rule 13a-14(a). In future filings, the certification should comply fully with Item 601(b)(31)(i) of Regulation S-K.
3. Response: We have made note of your comment. In future filings, the certification will comply fully with Item 601(b)(31)(i) of Regulation S-K.
If you have any questions or further comments, please do not hesitate to contact the undersigned or Ruba Qashu at (310) 208-1182 or via fax at (310) 208-1154.
Sincerely,
REED’S,
INC.
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CORRESP
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filename1.htm
REED’S,
INC.
13000
SOUTH SPRING STREET
LOS
ANGELES, CA 90061
November
19, 2008
VIA
EDGAR
United
States Securities and Exchange Commission
Division
of Corporation Finance
100
First
Street, N.E.
Washington,
D.C. 20249
Attn:
John
Reynolds, Assistant Director
Damon
Colbert, Staff Attorney
RE:
Reed’s,
Inc.
Post-Effective
Amendment No. 2 to Registration Statement on Form S-1
Filed
on October 31, 2008
File
No. 333-146012
Gentlemen:
Set
forth
below are the Company’s responses to the comments received from the staff
(“Staff”) of the Securities and Exchange Commission in the letter dated November
10, 2008. We have reproduced the Staff’s comments for your convenience and have
followed the comment with the Company’s response. References in this letter to
“we”, “our”, or “us” mean the Company or its advisors, as the context may
require. Capitalized terms not defined herein have the meaning set forth in
the
Registration Statement.
Risk
Factors, page 5
1. We
note
your response to comment one of our letter dated August 21, 2008 and the revised
disclosure on page 15. Please revise where appropriate to summarize the status
of the remediation efforts described on pages 38 and 39 of your Form 10-KSB
filed April 15, 2008. For example, in your Form 10-KSB, you describe remediation
efforts for different systems, reviews, procedures, and other items with
anticipated completion dates ranging from the second quarter of 2008 to the
fourth quarter of 2008. Please revise your registration statement to briefly
describe the status of these efforts.
Response:
We have
revised our registration statement accordingly.
Form
10-KSB/A for Fiscal Year Ended December 31, 2007
Page
1 of 2
Exhibits
2. We
note
that you changed the term “internal control over financial reporting” to
“internal controls” in the certification required by Exchange Act Rule
13a-14(a). In future filings, the certification should comply fully with Item
601(b)(31)(i) of Regulation S-K.
3. Response:
We
have
made note of your comment. In future filings, the certification will comply
fully with Item 601(b)(31)(i) of Regulation S-K.
If
you
have any questions or further comments, please do not hesitate to contact the
undersigned or Ruba Qashu at (310) 208-1182 or via fax at (310)
208-1154.
Sincerely,
REED’S,
INC.
/s/
Christopher J. Reed
Christopher
J. Reed
Chief
Executive Officer
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of 2