Correspondence 0001213900-24-095433 from IP STRATEGY HOLDINGS, INC. (IPST)
IP STRATEGY HOLDINGS, INC.
Date: Nov. 7, 2024 · CIK: 0001788230 · Accession: 0001213900-24-095433
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File numbers found in text: 333-279382
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CORRESP
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HERITAGE
DISTILING HOLDING COMPANY, INC.
9668 Bujacich Road
Gig Harbor, WA 98332
November 7, 2024
VIA EDGAR
Mr. Thomas Jones
Mr. Geoffrey Kruczek
Ms. Eiko Yaoita Pyles
Ms. Jean Yu
Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
Re:
Heritage Distilling Holding Company, Inc.
Registration Statement on Form S-1
File No. 333-279382
Ladies and Gentlemen:
Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Heritage Distilling Holding Company,
Inc. (the “Company”) hereby requests that the above-captioned registration statement (the “Registration Statement”)
be declared effective at 4:30 p.m., Eastern Time, on Tuesday, November 12, 2024, or as soon thereafter as may be practicable.
We acknowledge that a declaration
by the Commission or the staff, acting pursuant to delegated authority, that the Registration Statement is effective does not foreclose
the Commission from taking any action with respect to the Registration Statement. We further acknowledge that such a declaration of effectiveness
does not relieve the Company from our full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement.
We understand that we may not assert staff comments to the Registration Statement or the declaration of effectiveness by the Commission
as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Should you have any questions
regarding this matter or need any additional information, please contact the Company’s legal counsel, Eric M. Hellige of Pryor Cashman
LLP, at (212) 326-0846.
Very truly yours,
/s/ Justin Stiefel
Justin Stiefel
Chief Executive Officer
cc: Eric M. Hellige, Esq.