July 6, 2022

VIA EDGAR CORRESPONDENCE

Gregory Herbers

Division of Corporation Finance, Office of Manufacturing

United States Securities Exchange Commission

Washington D.C. 20549

Re: Reed’s, Inc.

Registration Statement on Form S-3 Filed June 24, 2022

File No. 333-265810

Dear Mr. Herbers:

Pursuant to Rule 460 and Rule 461 under the Securities Act of 1933, as amended, Reed’s, Inc., a Delaware corporation (the “Company”), hereby requests that the effective date of the above referenced Registration Statement be accelerated so that it will become effective at 4:00 p.m., Eastern time, on Friday, July 8, 2022, or as soon thereafter as practicable.

The Company acknowledges that:

● should the Securities and Exchange Commission (“Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

● the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

● the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact our counsel, Ruba Qashu, Raines Feldman LLP at 949-355-5405, with any questions or comments.

Very truly yours,

REED’S, INC.,

a Delaware corporation

/s/ Thomas J. Spisak

By: Thomas J. Spisak

Its: Chief Financial Officer