Correspondence 0001731122-24-001416 from Innovation Beverage Group Ltd (IBG) (CIK 0001924482) (IBG)
Innovation Beverage Group Ltd (IBG) (CIK 0001924482)
Date: Sept. 16, 2024 · CIK: 0001924482 · Accession: 0001731122-24-001416
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File numbers found in text: 333-266965
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CORRESP
1
filename1.htm
September
16, 2024
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, DC 20549
Attention: Mr. Evan Ewing
Re:
Innovation Beverage Group Limited
Registration Statement on Form F-1
Filed August 14, 2024
File No. 333-266965
Dear Mr. Ewing:
Pursuant
to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we, as representative of the underwriters
of the proposed initial public offering of securities of Innovation Beverage Group Limited (the “Company”), hereby join the
Company’s request that the effective date of the above-referenced Registration Statement on Form F-1 be accelerated so that it will
be declared effective at 4:00 p.m., Eastern Time, on Wednesday, September 18, 2024, or at such later time as the Company or its counsel
may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission.
Pursuant to Rule 460 under the
Securities Act, we, as representative of the underwriters, wish to advise you that there will be distributed to each underwriter, who
is reasonably anticipated to participate in the distribution of the security, as many copies of the proposed form of preliminary prospectus
as appears to be reasonable to secure adequate distribution of the preliminary prospectus.
The undersigned advises that it
has complied and will continue to comply, and that it has been informed by the participating underwriters that they have complied with
and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
[Remainder of Page
Intentionally Left Blank]
Very truly yours,
The Benchmark Company, LLC
By:
/s/ Michael S. Jacobs
Name:
Michael S. Jacobs
Title:
Head of Equity Capital Markets
cc:
Dean Huge, Innovation Beverage Group Limited
Richard A. Friedman, Sheppard, Mullin, Richter & Hampton LLP
Darrin Ocasio, Sichenzia Ross Ference Carmel LLP