Mail Stop 3561


									August 2, 2005

Mr. Yashpal Singh
Chief Executive Officer
Mendocino Brewing Company, Inc.
1601 Airport Road
Ukiah, CA 95482


      RE:		   Mendocino Brewing Company, Inc.
            	        	Form 10-K for Fiscal Year Ended
      December 31, 2004
      Filed May 13, 2005
	  	Form 10-Q for Fiscal Quarter Ended
		March 31, 2005
		Filed May 20, 2005
	File No. 001-13636

Dear Mr. Singh:

	We have reviewed your responses contained in the letter dated
July 18, 2005 and upon reviewing those responses issue the
following
comment.

	We welcome any questions you may have about our comment or on
any other aspect of our review.  Feel free to call us at the
telephone numbers listed at the end of this letter.


Form 10-K for Fiscal Year Ended December 31, 2004

Consolidated Statements of Operations and Comprehensive Income,
page
F-3
1. We read your response to comment 2 in our letter dated July 7,
2005.  Based on the additional information you provided, it
appears
to us that the legal dispute settlement represents an operating
expense, clearly related to transactions made during the ordinary
course of your operations.  In particular we note that the expense
relates to a dispute you had with a distributor of your product
and
transacting with your distributors is a normal part of your
continuing operations.  Thus, please tell us how you intend to
revise
your filing accordingly.  To the extent you amend your filing,
please
ensure the amendment also incorporates the revisions requested in
comments 5 and 6 in our letter dated July 7, 2005.

      As appropriate, please amend your filing and respond to this
comment within 10 business days or tell us when you will provide
us
with a response.  Please furnish a letter that keys your responses
to
our comment and provides any requested information.  Detailed
response letters greatly facilitate our review.  Please file your
response letter on EDGAR.  Please understand that we may have
additional comments after reviewing your amendment and response to
our comment.

	You may contact David DiGiacomo at (202) 551-3319, or in his
absence, Robyn Manuel at (202) 551-3823 if you have questions
regarding comments on the financial statements and related
matters.
Please contact me at (202) 551-3843 with any other questions.


                  Sincerely,



            George F. Ohsiek, Jr.
    					          Branch Chief



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Mr. Yashpal Singh
Mendocino Brewing Company, Inc.
August 2, 2005
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