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                                HART & HART, LLC
                                ATTORNEYS AT LAW
                             1624 Washington Street
                                Denver, CO 80203
William T. Hart, P.C.              ________           Email:  harttrinen@aol.com
Will Hart                                             Facsimile:  (303) 839-5414
                                (303) 839-0061


                                December 13, 2016


Ruairi Regan
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

      Re:   The Pulse Beverage Corporation
            Preliminary Proxy Statement on Schedule 14A
            File No 000-53586


Dear Mr. Regan:

     This office  represents The Pulse Beverage  Corporation.  We are writing in
reference to the staff's letter dated December 9, 2016. As you know, the purpose
of the  Company's  proxy  statement is to approve an amendment to the  Company's
Articles of Incorporation to increase the Company's  authorized  capital.  Under
Nevada law, any amendment to the Company's  Articles of  Incorporation  requires
the  approval  of  the  Company's  shareholders.  However,  Nevada  law  permits
shareholders owning a majority of the Company's issued and outstanding shares to
approve,  without  a  meeting,  any  matter  which  would  otherwise  need to be
submitted to the Company's shareholders.  Since the amendment to the Articles of
Incorporation must be approved by the Company's shareholders,  we do not believe
that Item 18 of Schedule 14A is applicable.

     Nevertheless,  we  believe  that the  staff  may be  curious  as to why the
Company  did not use an  information  statement  pursuant  to  Schedule  14C, as
opposed to a proxy statement  pursuant to Schedule 14A. The reason for this lies
in Rule 14c-2(b) which provides that an information  statement must be mailed to
the Company's  shareholders at least 20 calendar days prior to the date on which
the corporate  action may be taken.  In contrast,  if a proxy  statement is used
pursuant to Schedule A, a meeting of the Company's shareholders can be held, and
the  corporate  action can be  approved,  ten days after the proxy  statement is
mailed to the Company's shareholders.

     By using a proxy statement,  the corporate action, which in this case is an
amendment  to the  Company's  Articles of  Incorporation,  can be taken ten days
earlier than if an information statement is used.



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     If you should have any questions  concerning the  foregoing,  please do not
hesitate to contact the undersigned.

                                          Very Truly Yours,

                                          HART & HART, LLC

                                          /s/ William T. Hart

                                          William T. Hart























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