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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

Date
Jan. 31, 2025
Author
Stiefel
Form
CORRESP
Company
IP STRATEGY HOLDINGS, INC.

Letter

HERITAGE DISTILING HOLDING COMPANY, INC.

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

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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.