Correspondence 0001213900-25-008813 from IP STRATEGY HOLDINGS, INC. (IPST)
IP STRATEGY HOLDINGS, INC.
Date: Jan. 31, 2025 · CIK: 0001788230 · Accession: 0001213900-25-008813
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File numbers found in text: 333-284509
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CORRESP
1
filename1.htm
HERITAGE
DISTILING HOLDING COMPANY, INC.
9668
Bujacich Road
Gig
Harbor, WA 98332
January
31, 2025
VIA
EDGAR
Mr. Bradley
Ecker
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. 333-284509
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, February 4, 2025, 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.