SEC Comment Letter for Beeline Holdings, Inc. (BLNE) (CIK 0001534708) (BLNE) — Feb 13, 2017
Beeline Holdings, Inc. (BLNE) (CIK 0001534708)
Date: Feb. 13, 2017 · CIK: 0001534708 · Accession: 0000000000-17-005072
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3561 February 13 , 2017 Via E -mail Grover T. Wickersham Chief Executive Officer Eastside Distilling, Inc. 1805 SE Martin Luther King Jr. Blvd. Portland, Oregon 97214
Re: Eastside Distilling, Inc. Registration Statement on Form S -1 Filed February 1, 2017 File No. 333 -215848
Dear Mr. Wickersham:
We have limited our review of your registration statement to those issues we have addressed in our comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the requested information . Where you do not believe our comments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you provide in response to these comments , we may have additional comments. Liquidity and Capital Resources, page 35 1. Please provide an updated discussion of your liquidity needs, as it appears your disclosure in the fourth paragraph of this section refers to the December 31, 2016 fiscal year. Refer to Instruction 5 o f Item 303(a) of Regulation S -K and Section IV in Securities Act Release No. 33 -8350 for guidance. Executive Compensation, page 54 2. Please update your executive compensation disclosure to include the information for your recently co mpleted fiscal year. Refer to Item 402 of Regulation S -K and Regulation S -K Compliance and Disclosure Interpretation 117.05 for guidance.
Grover T. Wickersham Eastside Distilling, Inc. February 13 , 2017 Page 2
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Ruairi Regan at (202) 551 -3269 or Pamela Howell , Special Counsel , at (202) 551 -3357 if you have any questions.
Sincerely,
/s/ Pamela Howell
for
Show Raw Text
Mail Stop 3561
February 13 , 2017
Via E -mail
Grover T. Wickersham
Chief Executive Officer
Eastside Distilling, Inc.
1805 SE Martin Luther King Jr. Blvd.
Portland, Oregon 97214
Re: Eastside Distilling, Inc.
Registration Statement on Form S -1
Filed February 1, 2017
File No. 333 -215848
Dear Mr. Wickersham:
We have limited our review of your registration statement to those issues we have
addressed in our comments. In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
Please respond to this letter by amending your registration statement and providing the
requested information . Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments , we may have additional comments.
Liquidity and Capital Resources, page 35
1. Please provide an updated discussion of your liquidity needs, as it appears your
disclosure in the fourth paragraph of this section refers to the December 31, 2016 fiscal
year. Refer to Instruction 5 o f Item 303(a) of Regulation S -K and Section IV in
Securities Act Release No. 33 -8350 for guidance.
Executive Compensation, page 54
2. Please update your executive compensation disclosure to include the information for your
recently co mpleted fiscal year. Refer to Item 402 of Regulation S -K and Regulation S -K
Compliance and Disclosure Interpretation 117.05 for guidance.
Grover T. Wickersham
Eastside Distilling, Inc.
February 13 , 2017
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Ruairi Regan at (202) 551 -3269 or Pamela Howell , Special Counsel , at
(202) 551 -3357 if you have any questions.
Sincerely,
/s/ Pamela Howell
for
John Reynolds
Assistant Director
Office of Beverages,
Apparel and Mining
cc: Andrew W. Shawber, Esq.
Summit Law Group, PLLC