SEC Company Response from Beeline Holdings, Inc. (BLNE) (CIK 0001534708) (BLNE) — May 20, 2015

Beeline Holdings, Inc. (BLNE) (CIK 0001534708)
Date: May 20, 2015 · CIK: 0001534708 · Accession: 0001615774-15-001164

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File numbers found in text: 000-54959

Referenced dates: April 17, 2015

Date

December 31, 2014

Author

Director

Form

CORRESP

Company

Beeline Holdings, Inc. (BLNE) (CIK 0001534708)

Letter

Securities and Exchange Commission Re: Eastside Distilling, Inc. (the “Company”) Form 10-K for the Year Ended December 31, 2014 Filed March 31, 2015, as amended April 1, 2015 File No. 000-54959

Dear Mr. Spirgel:

In connection with the Company’s response to the comments of the staff (the “Staff”) delivered by way of it letter dated April 17, 2015 (the “Comment Letter”) being delivered by our legal counsel concurrent herewith, we hereby acknowledge that:

1. The Company is responsible for the adequacy and accuracy of the disclosure in the filing;

2. Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing ; and

3. 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.

Very
truly yours,
Eastside
Distilling, Inc.

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CORRESP
1
filename1.htm

EASTSIDE
DISTILLING, INC.

1805
SE Martin Luther King Jr. Blvd.

Portland,
Oregon 97214

May
20, 2015

Larry Spirgel

Assistant
Director

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

 Re: Eastside
                                         Distilling, Inc. (the “Company”)

Form
10-K for the Year Ended December 31, 2014

Filed
March 31, 2015, as amended April 1, 2015

File
No. 000-54959

Dear
Mr. Spirgel:

In
connection with the Company’s response to the comments of the staff (the “Staff”) delivered by way of
it letter dated April 17, 2015 (the “Comment Letter”) being delivered by our legal counsel concurrent herewith,
we hereby acknowledge that:

 1. The
                                         Company is responsible for the adequacy and accuracy of the disclosure in the filing;

 2. Staff
                                         comments or changes to disclosure in response to Staff comments do not foreclose the
                                         Commission from taking any action with respect to the filing ; and

 3. 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.

    Very
truly yours,

    Eastside
Distilling, Inc.

    By: /s/ Steven Earles

    Steven
Earles

    Chief
Executive Officer

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