Vodka Brands Corp
554 33rd Street
Pittsburgh, PA 15201
August 7, 2015
FILED ON EDGAR AS CORRESPONDENCE
United States Securities and Exchange Commission
Division of Corporate Finance
Washington D.C. 20549
Re: Vodka Brands Corp
Registration Statement on Form S-1
File No. 333-205398
To whom it may concern:
In accordance with Rule 461 under the Securities Act of 1933, Vodka Brands Corp, a Pennsylvania corporation (the “Registrant”), hereby requests acceleration of the effective date of the Registrant’s Registration Statement on Form S-1 (File No. 333-205398) (the “Registration Statement”), which was originally filed with the Securities and Exchange Commission (the “Commission”) on July 1, 2015, as amended. The Registrant respectfully requests that the Registration Statement become effective by 5:00 PM, Monday, August 10, 2015, Washington, D.C. time, or as soon as practicable thereafter.
The Registrant hereby acknowledges that:
(i) should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;
(ii) the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
(iii) the Registrant may not assert comments of the Commission or the staff and the declaration of effectiveness of the Registration Statement 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 further questions please do not hesitate to contact our attorney, Brenda Hamilton at 561-416-8956.
Sincerely
/s/ Mark T. Lucero
Mark T. Lucero
Chief Executive Officer
