United States securities and exchange commission logo





                              September 19, 2022

       Dean Huge
       Chief Executive Officer
       Innovation Beverage Group Ltd
       29 Anvil Road
       Seven Hills, NSW 2147
       Australia

                                                        Re: Innovation Beverage
Group Ltd
                                                            Amendment No. 3 to
Registration Statement on Form F-1
                                                            File No. 333-266965
                                                            Filed September 15,
2022

       Dear Mr. Huge:

             We have reviewed your amended registration statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Amendment No. 3 to Registration Statement on Form F-1

       Legal Opinion, page II-5

   1.                                                   We note the disclosure
on page 102 that the ordinary shares underlying the warrants are
                                                        being registered under
this registration statement. Please have counsel revise the Exhibit
                                                        5.1 legal opinion to:
                                                            Clearly disclose
that the offering includes the ordinary shares underlying the
                                                             underwriter's
warrants.
                                                            Remove assumptions
(h), (i), (j) and (l). Counsel should not assume that the registrant
                                                             has taken all
corporate actions necessary to authorize the issuance of the securities or
                                                             assume that the
registrant is not in bankruptcy.
                                                            Clearly opine that
the ordinary shares underlying the warrants will be, when sold,
 Dean Huge
Innovation Beverage Group Ltd
September 19, 2022
Page 2
              legally (or validly) issued, fully paid and non-assessable.
                Revise the opinion to address whether the ordinary shares are
non-assessable based
              on the meaning of that term under U.S. law.

         In addition, please list Australian legal counsel   s consent in the
exhibit list. Although the
         consent is not filed as a separate document, you may list it, then
refer to its location in the
         legal opinion filed as Exhibit 5.1. Refer to See Staff Legal Bulletin
No. 19 and Item
         601(b)(23) of Regulation S-K.

       You may contact Beverly Singleton at 202-551-3328 or Hugh West at
202-551-3872 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Evan Ewing at 202-551-5920 or Sherry Haywood at 202-551-3345 with any
other
questions.



FirstName LastNameDean Huge                                      Sincerely,
Comapany NameInnovation Beverage Group Ltd
                                                                 Division of
Corporation Finance
September 19, 2022 Page 2                                        Office of
Manufacturing
FirstName LastName