Mail Stop 3561


									January 9, 2006




Mr. Martin F. Roper
President and Chief Executive Officer
The Boston Beer Company, Inc.
75 Arlington Street
Boston, Massachusetts 02116


		RE:	The Boston Beer Company, Inc.
			Form 10-K for Fiscal Year Ended December 25, 2004
Form 10-Q for Fiscal Quarter Ended September 24, 2005
			Filed March 11, 2005 and November 3, 2005
			File No.  1-14092

Dear Mr. Roper:

		We have reviewed your filings and have the following
comments.  We have limited our review to only your financial
statements and related disclosures and do not intend to expand our
review to other portions of your documents.  Where indicated, we
think you should revise your disclosures in response to these
comments.  If you disagree, we will consider your explanation as
to
why our comment is inapplicable or a revision is unnecessary.
Please
be as detailed as necessary in your explanation.  In some of our
comments, we may ask you to provide us with information so we may
better understand your disclosure.  After reviewing this
information,
we may raise additional comments.

		Please understand that the purpose of our review process
is
to assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments 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 25, 2004

Consolidated Statements of Cash Flows, page 30

1. Please revise your presentation in future filings to include
the
proceeds from the sale of trading securities as an operating
activity.  See paragraph 18 of SFAS 115.

Notes to Consolidated Financial Statements, page 32

B. Summary of Significant Accounting Policies, page 30

Segment Reporting, page 34

2. Please tell us why you believe that aggregation of your product
line operating segments is consistent with the provisions of
paragraph 17 of SFAS 131.  In particular, tell us how the business
units are similar in terms of their economic characteristics.
Please
provide along with your response the revenues and gross margins
for
your business units for the last 5 years and demonstrate how that
information supports the similarity of the economic
characteristics
of the operations.  If after reassessing the criteria in SFAS 131,
you now believe that each of these operations represents a
separate
reportable segment, please revise your financial statements
accordingly.

Item 9A. Controls and Procedures, page 51

3. You state that your Chief Executive Officer and Chief Financial
Officer evaluated the effectiveness of your disclosure controls
and
procedures.  However, your chief executive and financial officers
only concluded that your disclosure controls and procedures "were
effective to provide a reasonable level of assurance that the
information required to be disclosed in the reports filed or
submitted by [you] under the Securities Exchange Act of 1934 was
recorded, processed, summarize and reported within the requisite
time
periods."  Please confirm for us, if true, that the same officers
concluded the controls and procedures were effective in ensuring
that
information required to be disclosed by an issuer in the reports
that
it files or submits under the Act is accumulated and communicated
to
the issuer`s management, including its principal executive and
principal financial officers, or persons performing similar
functions, as appropriate to allow timely decisions regarding
required disclosure.  Your confirmation of the preceding
information
applies to both your annual report and each of your subsequent
quarterly filings.  Please also disclose which definition of
disclosure controls and procedures you used in performing your
assessments.  See Items 307 of Regulation S-K and Exchange Act
Rule
13a-15(e) for guidance.  Notwithstanding your response to this
comment, please ensure your future filings provide the appropriate
disclosures.

Exhibits, page 55

Exhibits 3.2

4. Please provide us with and revise future filings to include a
complete copy of your articles of incorporation, as amended.  Your
current incorporation by reference to Exhibit 3.6 to Form 10-Q
filed
August 10, 1998 only refers to an amendment to the articles of
incorporation.  Refer to Item 601 (b)(3)(i).

Exhibits 31.1 and 31.2

5. Please confirm that the inclusion of your Chief Executive
Officer
and Chief Financial Officer titles was not intended to limit the
capacity in which such individuals provided the certifications.
In
the future, eliminate reference to the CEO and CFO`s titles in the
introductory paragraph of the certifications to conform to the
format
provided in Item 601(b)(31) of Regulation S-K.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please understand that we may have additional comments after
reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

		In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.

		If you have any questions regarding these comments,
please
direct them to Anthony Watson, Staff Accountant, at (202) 551-3318
or, in his absence, to me at (202) 551-3843.

									Sincerely,



									George F. Ohsiek, Jr.
									Branch Chief
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Mr. Martin F. Roper
The Boston Beer Company, Inc.
January 9, 2006
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