SecProbe.io

April 17 , 2015

Steven Earles
Chief Executive Officer
Eastside Distilling, Inc.
1805 SE Martin Luther King Jr. Boulevard
Portland, Oregon 97214

Re: Eastside Distilling, Inc.
Form 10 -K for the Year Ended December 31, 2014
Filed March 3 1, 2015, as amended April 1, 2015
  File No. 000 -54959

We have reviewed your filing an d have the following comments.  Please comply with the
following comments in future filings.  Confirm in writing that you will do so and explain to us
how you intend to comply.   In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your r esponse.

After reviewing your response to these  comments, we may have  additional comments.

Liquidity and Capital Resources, page 28

1. We note your disclosure on page 28 regarding the $150,000  loan between Eurocan
Holdings Ltd. and Eastside Distilling, LLC on June 13, 2014.  Please  also provide
disclosure about the $150,000 non -interest bearing, unsecured, demand loan from Crystal
Falls LLC to Eurocan Holdings, Ltd. made on t he same date.  Disclose any relationship
between the parties to the loans and the role of Crystal Falls LLC in the reverse merger
transaction.  Disclose why Eurocan Holdings Ltd. took out a loan to provide the loan to
Eastside Distilling, LLC.  Explain the  business purpose of structuring the loans in this
manner.  Explain why the loan from Crystal Falls  LLC was amended to add new terms
including interest, conversion rights, a maturity date and a pre -payment penalty .  Also
explain why the promissory note fro m Eastside Distilling, LLC was stated to be
convertible when it was non -convertible and why the original demand note references
Crystal Falls LLC, but the amended note now refers to Crystal Falls Investment LLC.

Steven Earles
Eastside Distilling , Inc.
April 17 , 2015
Page 2

 Notes to Consolidated Financial Statem ents
Note 3.  Acquisition, page F -12

2. Please  expand your disclosure either here or in another footnote to disclose the impact on
your financial statements of the spinoff of MWWD.

Note 8.  Income Taxes, page F -14

3. Please tell us your basis for your disclosure that at December 31, 2014, you had federal
and state net operating loss carryforwards (NOLs) of approximately $367,000 and
$366,000, respectively, to offset against future income for federal and state tax purpo ses.
We note that these probably related to Eurocan and may be affected by the change in
control resulting from the merger.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the co mpany
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;
 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect t o the filing; and
 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Sharon Virga, Staff Accountant , at (202) 551 -3385  or Terry French,
Accountant Branch Chief,  at (202) 551 -3828  if you have questions regarding comments on the
financial statements and related matters.  Please contact  Gregory Dundas, Attorney -Advisor, at
(202) 551 -3436, Kathleen Krebs, Special Counsel, at (202) 551 -3350, or me at (202) 551 -3810
with any other questions.

Sincerely,

 Kathleen Krebs, for

Larry Spirgel
Assistant Director

cc: Greg Carney
Indeglia & Carney, LLP