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CORRESP
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filename1.htm

THE3RDBEVCO,
INC.

December
22, 2022

VIA
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

100
F. Street, N.E.

Washington,
D.C. 20549

    RE:
    The3rdBevco Inc.

    Offering Statement on Form 1-A

    Filed November 17, 2022

    File No. 024-12066

Ladies
and Gentlemen:

On
behalf of our Company, The3rdBevCo, Inc., (the “Company”), we are filing with the Securities and Exchange Commission (the
“Commission”), Amendment No. 1 to the offering statement on Form 1-A (“Amendment No. 1”) for the registration
for securities.

This
letter also sets forth the Company’s responses to comments from the staff (the “Staff”) of the Division of Corporation
Finance of the Commission contained in the Staff’s letter dated August 19, 2020 regarding your review of the offering statement
on Form 1-A, which was filed with the Commission on July 24, 2020.

For
your convenience, the Staff’s comments have been repeated below in their entirety, with the Company’s response to a particular comment
set out immediately underneath it. The headings and numbered paragraphs in this letter correspond to the headings and numbered paragraphs
in the comment letter from the Staff. When indicated, the responses described below are included in Amendment No. 1. Capitalized terms
used but not defined in this letter are intended to have the meanings ascribed to such terms in Amendment No 1.

Form
1-A filed November 17, 2022

General

1.
We note that you were late filing your Form 1-K for the fiscal year ended December 31, 2021, which was due 120 calendar days after the
end of the fiscal year covered by the report. We also note that you were late filing your Form 1-SA covering the first two quarters of
2022, which was due 90 days after the end of the second quarter. To engage in a continuous offering under Regulation A, you must be current
in the annual and semiannual filings required by Rule 257(b) at the time of each sale. Refer to the last sentence of Rule 251(d)(3)(i)(F)
of Regulation A. Please tell us whether offers and sales were made during your period of delinquency, and, if so, provide your detailed
analysis how any sales complied with Regulation A and were not made in violation of Section 5 of the Securities Act of 1933. Add a risk
factor to address the risk of potential Section 5 liability.

The
Company’s Form 1-A offering was not current for the period from May 1, 2022 through November 12, 2022 (“non-compliance period”)
as it had not timely filed Forms 1-K and 1-SA. The Company was unable to keep current with its periodic reporting requirements due to
changes in auditors and scheduling delays outside of its control which caused the Company to not file Forms 1-K and 1-SA on time. During
the non-compliance period, the Company offered its common stock for sale through its Form 1-A Tier 2 offering at a price of $1.00 per
share, issued 545,388 shares and received investor proceeds of $545,388 (net of $28,156 paid to our platform provider Dealmaker). The
Company ceased all sales of securities on November 10, 2022, and does not intend to resume sales of securities under this offering until
it current with its periodic reporting requirements under Regulation A and Form 1-A is requalified. As a result of non-compliance with
Section 5 of the Securities Act of 1933, it is possible that the Company could face a potential liability for the sales of securities
during its non-compliance period.

We
have added a risk factor accordingly.

THE3RDBEVCO,
INC.

2.
We note that your website includes a 10% bonus share award for certain investment tiers. Please revise your offering statement accordingly
to include disclosure related to such bonus share awards.

We
have removed any reference to a 10% bonus from the website.

If
you have any questions or comments regarding these responses or require any additional information, please do not hesitate to contact
me or our counsel, Smith Eilers, PLLC. at (561) 484-7172.

    Very truly yours,

    /s/ Peter Scalise

    Peter Scalise, CEO

    The3rdBevCo, Inc.

 cc: William
R. Eilers, Esq.