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From Journalism to Beverage Law โš–๏ธ๐Ÿฅƒ | Ryan Malkin's Legal Startup Guide for Alcohol, NA, THC & CBD Brands

โ€ข Jessie Ott

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Ryan Malkin breaks down legal tips for launching alcohol, non-alcoholic, THC & CBD brands. Co-packing, DTC, trademarks, & more! ๐ŸŽ™๏ธ๐Ÿ’ผ 

Watch now on Thirsty Thursdays @ThirstyThursdaysat3PMEST

https://youtu.be/l5uyOu7b4yA

"How to start an alcohol brand legally"

๐Ÿ“˜ Video Summary with Key Takeaways:

In this episode of Thirsty Thursdays, host Jessie Ott sits down with Ryan Malkin, Principal Attorney at Malkin Law and creator of Set the Bar, to provide a comprehensive legal roadmap for launching any type of beverage brand โ€” alcoholic, non-alcoholic, or cannabinoid-infused. ๐Ÿท๐Ÿน๐Ÿ‹๐ŸŒฟ

๐Ÿ’ก Key Takeaways:

  • โœ… Co-packing vs. self-manufacturing
  • ๐Ÿงพ The truth about distribution contracts
  • ๐Ÿšซ Common legal pitfalls (and lawsuits!)
  • ๐Ÿ›๏ธ DTC shipping laws by state
  • ๐Ÿ“ฆ Labeling and compliance mistakes
  • ๐Ÿ” Why trademarks should be filed early
  • ๐Ÿ“ฑ Modified DTC and the truth about Flaviar, GoPuff, Drizly
  • ๐ŸŒฟ Hemp vs. Marijuana-derived THC
  • ๐Ÿง  ADA compliance & website lawsuits
  • ๐Ÿ’ฌ How to build a support network that keeps you protected

This is a must-watch for beverage entrepreneurs navigating today's regulatory minefield โ€” with actionable advice, real-world examples, and a dose of wit. ๐Ÿง ๐Ÿฅƒ๐Ÿ’ฌ

๐Ÿ“ฃ CTA (Call To Action):

๐Ÿ’ฅ Like this episode? Smash that like ๐Ÿ‘, subscribe ๐Ÿ””, and share with a founder who needs legal clarity!


 ๐Ÿ“ฅ Download your free legal startup cheat sheet
                  Alc and Non Alc       Hemp THC

 ๐Ÿ“ Reach out to Ryan via https://www.malkinlawfirm.com/  and follow us @ThirstyThursdaysat3PMEST



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I need a YouTube post for this transcript: Jessie Ott (00:01.39)
Hello everybody and, live stream. No, we're not live streaming. Hello everybody and welcome to Thursday Thursdays. am Jessi Ott and I have Ryan Melkin, Principal Attorney of Melkin Law and founder of Set the Bar. Hey Ryan, welcome.

Ryan (00:19.414)
Thank you, how's it going? Thanks for having me.

Jessie Ott (00:21.512)
yeah, I'm super pumped to have you here. You've come up on podcast here and there. I, I know you've been on Erica's show a couple of times and had some awesome discussions and, and talked about a lot of different things in regards to, know, obviously a lot of new beverage companies have launched the last few years and I'm sure you it's kept you very busy. And, one of the things that I talked to Ryan about, before we kind of got him on the show.

here is to kind of give the audience a guide on different beverage beverages instead of kind of just walking kind of talking through it. Maybe do it a little in a little bit more structured way. So hopefully, you know, people will remember one and two that will have a will have a downloadable document depending on whatever, you know, option they're they're looking at building, whether that's, you know, non elk.

or RTD or alcohol or THC or CBD because they all have their own laws. Right. And even with NABEVS, I understand like just talking to athletic, the guys over at Athletic Brewing that there are still some stickiness with shipping online and that type of thing. So, Ryan, where are you calling from?

Ryan (01:43.22)
I'm in my office in Miami, So great weather today and happy to be here.

Jessie Ott (01:50.722)
Yeah, it is. It's a pretty nice in Orlando too. It's hot. It's going to be in the nineties, two weeks early.

Ryan (01:56.576)
Yeah, yeah, it's definitely getting hot in the afternoons, right now, good to go.

Jessie Ott (02:00.812)
Yeah, it's pretty nice. agree. So is that where you're from? Are you from Miami area?

Ryan (02:07.07)
No, I grew up actually in Michigan and then after undergrad, I moved to New York to be a writer actually. So I was a journalist and I was a staff writer at Smart Money Magazine, which, and not closed, but it was a Wall Street Journal publication. And I did a lot of the, the lifestyle stuff. So I wrote about alcohol and trends and like, what's the best, you know, whiskey to buy your father for Father's Day. And then I did a lot of freelance writing for magazines and did.

roundups and trend pieces. like for beverage media or Santa or liquor.com, know, Esquire and what have you.

Jessie Ott (02:43.64)
That's really cool. Did you meet Erica back then?

Ryan (02:47.88)
I did a little bit, well not then, but I did work with her a little bit more when I was a lawyer. But I did a lot of alcohol beverage writing and that's kind how I really got into the industry more on the business side.

And that's actually sort of how I connected with my wife actually, who has a public relations agency in the alcohol beverage industry called CultureWise Collective. So funny enough, I sort of was emailing her as a journalist prior to being a lawyer. So anyway, I was in New York for about 15, 16 years. I was a writer, like I said, and then after maybe four or five years of being a writer, I went to law school at night.

Jessie Ott (03:22.702)
interesting.

Ryan (03:34.046)
and continue working. I went to Brooklyn Law School that night.

Jessie Ott (03:34.2)
Where did you go?

Nice. One more question. Being from Michigan, which school did you go to?

Ryan (03:43.306)
I went to University of Michigan, go blue.

Jessie Ott (03:46.324)
Okay. I'm a Hawkeye. So not that it matters anymore because a Big Ten is such a mess, but yeah, we used to be really big rivals back in the, back in the, you know, the cool days of the Big Ten. Yeah. Nice.

Ryan (03:59.51)
Yeah, yeah, So yeah, so I was a writer in New York and then I went to law school at night, kept writing during the day. And then after law school, I ended up going to the New York County DA's office, so the Manhattan DA's office.

Jessie Ott (04:17.453)
That's awesome.

Ryan (04:19.308)
And I took a complete sort of turn, right? Instead of continuing in the publishing world. However, I kept doing a little bit of freelance work during that time, continuing to keep my foot in the door, toe in the water, whatever you want to say. In the alcohol world, doing some freelance writing. Again, still trend pieces, things like that. And then...

Jessie Ott (04:25.175)
Yeah.

Jessie Ott (04:43.544)
So what was it like to work in the DA?

Ryan (04:47.004)
it was awesome. I loved working there. You know, they give you a lot of responsibility and you you can certainly, you know, control whether or not someone goes to jail basically or does community service. And, know, it's great because you can certainly make sure that people, are prosecuted if they need to be, or you can be more lenient if you don't think they need to be. So, I mean, it's definitely a lot of control, which is great. And you can use your discretion, but it was awesome being on trial. And I mean, it's a, a very fun job and.

Jessie Ott (04:58.412)
Yeah!

Ryan (05:17.024)
you know, very, to use like a Pranavra card term, convivial, like it was a very convivial environment where everybody hung out a lot and went out after work. And so it was definitely an awesome place to work. And then after about five or so years there, that's when I went out in-house to Pranavra card.

Jessie Ott (05:33.902)
That's great.

Ryan (05:41.536)
because I wanted to get into the legal side of alcohol, because I really just love the industry from the business side. And I had a lot of friends in the industry because of being on the PR side and going on press trips and all that. And that's kind of when I started on the road of being an alcohol beverage attorney. And then after several years there,

My wife and I moved to Miami because she grew up here. So that's when I started my practice, Malcolm Law, about 11 years ago now. So long version of getting to why I'm in Miami now.

Jessie Ott (06:13.365)
wow. 11 years. That's good. That's great. Congratulations.

Jessie Ott (06:20.716)
Yeah, well, that's really cool. Did you have any mentors that you'd want to mention that kind of helped you, whether it was in transition or at the DA or, you know?

Ryan (06:30.816)
Well, I I really loved all of my supervisors, which was great. you know, Paul Finch was the editor at Smart Money who gave me the, my first basically job in journalism. And he was, you know, great. And then at the DA's office, you know, Gene Procaro was my supervisor and he was awesome.

you know, explained obviously everything and, you know, he was a great supervisor and mentor for a lot of people. And then when I went to Pernaut, Tom Lalla and Carolyn McNerney were my supervisors. And, you know, the reason I got the job partially, which is kind of a good, maybe thought for, for anybody trying to get a position, I looked up his bio and I don't know, was LinkedIn or wherever it was, maybe on the website. And he was a former prosecutor.

So I actually just reached out to him kind of randomly and was like, hey, I'm currently a prosecutor. I'm thinking of leaving. I love the alcohol beverage industry. I used to write about it. So I know the business side, but like, know, candidly, I don't really know any of the legal side.

Can we just get together and can you explain to me how you transitioned from the DA's office to this world and we got together and it just so happened that, you know, he had something that he thought I'd be suitable for. So just as a way, by way of example, if you're looking at a, you know, position you really want or transitioning, looking at people and kind of their background and finding a...

Jessie Ott (07:59.523)
Yeah.

Ryan (08:02.132)
a common kind of is maybe a good idea. And I know that prosecutors, certainly in Manhattan, but anywhere really kind of have that thing where you can be like, was a prosecutor too, you know, and they kind of know what you've been through and usually are helpful and, you know, happy to get together, even though we work in the same offices.

Jessie Ott (08:22.092)
That's great. Yeah. That's some great advice right there. That's really cool. What a great idea.

Ryan (08:30.924)
And then I transitioned in the current GC. Brian Shevlin is great and we transitioned or we were kind of overlapping for like maybe a year or so.

Jessie Ott (08:43.234)
Okay. Any resources that you recommend?

Ryan (08:48.234)
I mean, well, for what? Just generally for.

Jessie Ott (08:51.576)
Well, for industry knowledge and or potentially law information.

Ryan (08:57.246)
Yeah, so I I started Set the Bar, which is an app a few years ago, and the idea came to me because clients were asking me to create like state cheat sheets, right? So, you know, New York, Florida, whatever, where they had salespeople, and it would be basically a Word document with maybe the top 10 or 12 things that they need to know in that state. So for instance,

you know, can you do an on-premise tasting, off-premise tasting, what's the maximum you can give in displays, what have you. And I was doing those and finding that, you know, salespeople largely don't want to carry around, you know, a Word document, whether it's physical or on their phone, they don't use it. So I created this app to have similar information and make it an

Jessie Ott (09:40.93)
Yeah. Yeah.

Ryan (09:46.7)
really easy to use form, like is it okay green, is it not okay red, is there caution, it's like a maybe yellow, right? And then you can click more and then it has a little bit more of the rules and the details behind it and kind of an easy to read format. So that's one resource office that we direct clients, a lot of them use it and people who are not our clients also use it.

Jessie Ott (10:06.636)
Yeah, that's a great one.

Ryan (10:12.362)
And then beyond that, you know, signing up for the bulletins like the TTB has a great newsletter that if you sign up for that on the TTB website, they'll shoot you an email when there's changes. And this, a lot of the states have the same thing. So if you're in a state, I would encourage you to sign up for the, you know, ABC SLA or equivalent newsletters and TTB too.

Jessie Ott (10:34.574)
Okay, awesome. So from your perspective, know, what are the main pain points that companies are experiencing that they come to you when it's too late?

Ryan (10:49.112)
Usually it's something that's, you know, gone wrong. Let me step back and say, I always encourage people to reach out early.

it's typically easier to address questions or issues before they happen. But people will call and be like, hey, and this happens all the time. We signed this distribution agreement while we were just getting started. We didn't feel like we had a lot of leverage, so we just signed it. We didn't honestly really read it. No lawyer reviewed it. Or maybe, you know, my cousin or uncle who's a whatever, real estate lawyer or something, read it. And it was like, okay, fine.

The same thing happens with COPAC agreements, contract bottling agreements. And then there's a dispute now. Sometimes it's good, right? Like, hey, we have a national alignment with a big distributor. How do we get out? Or these guys are terrible and we can't get out. So those are the issues that often come up on the distribution side. And then on the COPAC side, it's typically that there was something wrong, right? Like,

All of my cans are exploding or there's like something gross in the, you know, the product and there's glass, whatever it is. And we're the client. didn't actually touch anything. didn't copack it. never, we didn't make anything. We're just a brand company. The copack are saying, no, it's not our responsibility. The glass or the can company and the, all the parties are pointing their fingers being like it's somebody else. Meanwhile, you don't have a

product in the market and you're the one that is kind of holding the back. So resolving those things as clearly as possible in contracts is obviously better, right? All of these things are sort of like prenups and looking at the worst case scenario now.

Jessie Ott (12:40.078)
Okay. And then what about, you know, the outlook for the industry? There's been a lot of rumble and tumble and We Go Vee is taking away, you know, everybody's interest in drinking, but no, it's actually, fine. It's kind of this yo-yo effect of is it healthy or is it not? Do you have any, you know, thoughts on that?

Ryan (13:07.648)
I mean, people say that and obviously there are clients where they're saying that they're having a difficult time finding additional fundraising, which is certainly something that's happening and I'm aware of that. I certainly still have a positive outlook. Like we still have clients who are starting brands. I think that...

you know, long-term, I don't foresee people necessarily stopping drinking despite the current trend. Maybe people will drink a little bit less, but you know, I still, when I've been going out, people are still going to the bars. They're still lining up to get beer at concerts, right? Like, so...

still very optimistic even if there's more options in terms of the non-alcohol world which is great right like I've been trying some non-alcoholic spirits that are actually like really really good and you know that's great. What's that?

Jessie Ott (13:58.114)
Which ones?

Which brands have you tried that you like?

Ryan (14:03.904)
Well, there's a couple that are launching that I think are really, really great. And I will certainly let you know when the time is right. But there's some that are much, much, much better than I think others. Same with beer, right? Like I've been trying a lot of non-alcoholic beers and it's been...

Jessie Ott (14:16.576)
Okay. Okay.

Jessie Ott (14:21.665)
Okay.

Ryan (14:28.672)
You know, those are great options too. So just cause you don't drink every single day, which, you know, probably is not the best thing alternating. And I, I'm super optimistic for, for both the non alcohol and alcohol.

Jessie Ott (14:42.2)
Yeah, me too. I mean, we've only been doing this for 8,000 years. Wine's been around 8,000 years. don't think there's going to be that big of a bump in the road. Anyway, that's good. Good positive outlook is always good thing. Yeah, I mean, that's the one thing about the industry is it's recession proof. know, people may trade down, but they're not going to stop. And you know, what we're seeing now is they're trading, right? So,

Well, I can't drink or I don't want to drink, but I can get THC and CBD and, you know, and or they take gummies or whatever the case may be. I feel like they may just be trading on and off, you know, for something else.

Ryan (15:26.314)
Yeah. And I mean, I personally think that COVID was a high point, right? In terms of the amount people were drinking. perhaps now it's just, and again, I'm not looking at the stats, so this is more like anecdotal than statistical. But I think people just are kind of getting back to a baseline versus like that high drinking pretty regularly during COVID.

Jessie Ott (15:38.882)
Right. Yeah.

Jessie Ott (15:52.94)
Yeah. Yeah. You mean when it went like this? Where everybody bought Bailey's because they had it in their coffee every morning for a year and a half. That was pretty funny. That was pretty funny. so that's, wow, we got through that really fast, but Ryan, so congratulations on your career. That's really exciting to have your own business for 11 years. And, you know, I can't wait to dig into.

Ryan (15:56.427)
Yeah.

Ryan (16:20.652)
It's fun.

Jessie Ott (16:20.874)
our next phase of the interview here. And that's kind of us talking about the different, you know, non-ELK, alcohol, CBD and THC, the rules and laws because they are, they do vary by type. And then I think what we'll do is we'll just start off by kind of just talking about the basics of starting a brand, whatever it is, right? Cause there's going to be some overlap on how you kind of approach that piece. So when...

Maybe we come up with a name of a person to use as an example of a brand that they want to create. So do you have a name that pops into your brain at all?

Ryan (17:00.204)
I mean, can, know, Jesse's whiskey or Jesse's whatever.

Jessie Ott (17:03.67)
It's Jesse's whiskey. Okay. Jesse's whiskey. I'm making a whiskey. Okay. Let's start there. What do I do?

Ryan (17:07.756)
Yeah.

So it's actually pretty, yeah, yeah, it's actually a little bit assembly line-ish. And what I mean by that is you form a company and you can talk to an accountant, but a lot of people will form an entity in Delaware, especially if they're taking on investors. If they're not, maybe they'll just form in whatever state they are. Get an EIN number so they can open a bank account. And then...

Jessie Ott (17:35.81)
Why would Delaware be more of an investor state?

Ryan (17:40.564)
Investors like Strategics and VCs, Private Equity, etc. tend to prefer Delaware just because the laws are favorable and there's a lot of precedent regarding corporations there. So a lot of corporations like, you know, lot of the publicly traded companies are, you know, Delaware companies. And then you'll do a foreign filing, meaning that you're, although you're a Delaware company, you're filing to do business in the state of Florida, let's say, right? So, but in your case, if you're a small company and it's just,

you and maybe a couple of friends that you raise money from and you're in Florida, maybe you sort of file a Florida LLC, let's say. And the question now is, are you gonna become a distillery and distill it yourself or more likely than not, you're going to co-pack? So if you're gonna co-pack, then you're gonna obviously need a contract with the co-packer and you have to figure out your route to market.

During this time, you would also be filing for your trademark, right? So it takes a long time for the USPTO to look at your application, like nine to 12 months in some cases. Which is not to say you can't use it. Yeah, but that doesn't mean you can't use the name. It just means that you should pick a great name, ideally. Like we'll run a clearance search and see, you know, is it completely clear there's nobody, because you made up the name, right? Like a Google or a Yahoo or whatever, like that they brought.

Jessie Ott (18:49.565)
my gosh. Seriously? Whoa.

Ryan (19:08.556)
to the name or are you something that's actually not a very good name for a whiskey, Jesse's whiskey. So probably not a good name actually for trademark purposes, especially if it's named after you. But in any event, you would file the trademark.

Jessie Ott (19:27.362)
What about Thursday Thursday's whiskey?

Ryan (19:29.824)
Right, much better probably. So then you would file that, you'd enter into the contract like I said with a co-packer. You gotta figure out your route to market, right?

Jessie Ott (19:31.63)
You

Jessie Ott (19:41.772)
Well, can we back up a second? Like, what's a co-packer and why do I need one of those?

Ryan (19:46.828)
So if you're not gonna distill it yourself, then somebody has to make it for you with a distilling license or bottling, right? So maybe you buy it or gonna get it from Kentucky or Tennessee or somewhere and then you would transfer it to the bottling facility in Florida, if you're gonna bottle in Florida, let's say. So somebody with appropriate licenses has to ultimately either distill it or bottle it for you. You can...

Jessie Ott (20:13.09)
Yeah. Okay.

Ryan (20:15.21)
Get your own license, but that was, there's a lot of startup costs to rent a location, get stills, like fermentation tanks, and that's a whole thing. You can also do what they call an alternating proprietorship where in some states and certainly federally you can, that you are a tenant at another person's distillery, but you would get all the same licenses. But most people start by co-packing. If they...

Jessie Ott (20:24.983)
Yeah.

Jessie Ott (20:43.032)
Yeah, I mean, that's how TX started. When I think back to that whiskey trend, I feel like TX was one of the early ones to get the MGP juice, right? Bottle it in their own bottle, maybe age it, whatever they wanted to. And then that's how they built their business. That's then...

Once they had that going, it offered them more cash to buy more barrels to start doing their own, right?

Ryan (21:14.572)
That's a common way to do it for sure, especially if you want the tourist destination and the tasting room and stuff like that.

Ryan (21:25.13)
But no, you're completely right. Most brands will start with like MGP juice or something like that. And then maybe do something unique to it. Maybe not put it in their own bottle with their own label and hope for the best. The whiskey market is obviously tougher than it was in the past, but by way of example, it would be similar. So you would find the right person to bottle it in any case.

whether it's distilling and bottling maybe for a gin or a vodka, receiving older juice from somewhere else, probably for a whiskey. And you would make sure that the contract is reviewed hopefully by a competent attorney that works in this space. And so what I mean by the distribution plan though is it's harder and harder for smaller brands to find distributors, especially the Southern R &DC breakthrough tier.

A lot of people will start with smaller distributors, which could be like a Park Street or an MHW or Meridio or Elentene or something like that, where they kind of offer back-end compliance solutions and will warehouse the product and then ultimately deliver it, but don't have salespeople, right? So I'm sure everybody knows or should know if they're getting into this industry that most distributors at the smaller level, for smaller brands meaning, are not really

doing that much, it's largely more of a delivery truck. So you should be willing and able to run around town and try to get your product into accounts, right? So I wouldn't rely on a distributor to do that work for you. So assuming you start with one of these like kind of compliance distributors that are doing the work but not having the salesperson.

That's great, then you can decide based on your state what firm permits you'll need. Certainly be a federal permit at the very minimum, a federal basic wholesale permit, and then likely some state permit. And then you're kind of off and running, and then you focus on things like...

Ryan (23:29.664)
you know, your website, are you gonna have some sort of modified DTC option? Are you going to, you know, have social media presence? Like what are the marketing activities you're gonna do? So, and that's where we help out and we'll look at your website, draft terms and conditions and privacy policies, look at your social media. If you have like a really cool activation, we'll, you know, look at it, you know, all that kind of stuff.

Jessie Ott (23:52.13)
Yeah, and I feel like there's been some changes recently with direct to consumer shipping. If I'm not mistaken in New York or Pennsylvania. Is that right?

Ryan (24:02.464)
So, yeah, so obviously wine is quite easy and pretty widespread. For spirits, it's pretty minimal. However, there are some states in New York past DTC, it's allowed interstate and allowed interstate where there's reciprocity, but with other states, but there's a lawsuit, you're right. I think that's what you maybe referring to.

where they're basically challenging the reciprocity requirement. But if you're in New York and you're a distiller in New York and your customer's in New York, you're good to go and can send it to that person DTC like a one or he could, which is awesome.

Jessie Ott (24:43.852)
Yeah. Yeah. Which is super awesome. Yeah. how many states is there states that aren't allowing you to, to ship spirits currently?

Ryan (24:56.31)
Well, like as an example, like distilleries in Florida can't sell to Florida consumers, DTC. And there's a lot of States. mean, I would say more States than not, don't allow distilleries to ship DTC to even in the state, let alone interstate. So yeah, you know, I'm counsel for American craft spirits association, and we've been pushing for, you know,

Jessie Ott (25:13.962)
Okay, so that's still kind of on lockdown.

Ryan (25:23.84)
DTC on the spirit side for years. mean, it just makes sense. It doesn't, in my opinion, really take away significant revenue from distributors. It actually helps, right? So like, if I'm in Florida and I'm allowed to ship DTC, if I'm sending a couple of cases to California or New York or Michigan or something,

You know, is that really going to, and I don't even have distribution in there. that really going to take away from a distributor's margins? And then B, maybe it's like, I'm getting so many orders in California that I'm like, maybe I should find a distributor and then distributor. Right. Right. So I mean, that's great. And then you go to find, go find a distributor. now all of a sudden you're like, Hey, distributor, like, we have a ton of interest here.

Jessie Ott (25:54.454)
Right. Right.

Jessie Ott (26:05.176)
Well, that's just it. That's how it could happen. Yeah.

Ryan (26:17.036)
Now somebody could go to a liquor store and buy a product too and, you know, the on-premise. So, I'm all for it.

Jessie Ott (26:25.228)
Yeah, well what about websites like Flavier?

Ryan (26:29.578)
So whether it's them or there's a bunch of other alternatives, obviously out there where basically I think what you're talking about, well, let me ask you, are you talking about where you go to like a storefront, know, an Amazon style storefront or where it's modified DTC where you're going to the brand website, but getting it delivered?

Jessie Ott (26:54.508)
Yeah, brand website, getting it delivered.

Ryan (26:57.312)
So basically what happens is on those, there's a third party provider and on the back end, you you add it to the cart and that third party provider is choosing liquor stores based on their relationships in, you know, different states. So they'll send that order to a liquor store in, you know, let's say New York and that liquor store in New York will actually just deliver the product.

There are cases where some liquor stores and some websites will rely on what they call the title theory. So the idea is, I'm in Florida, title's taking place in Florida at this liquor store, but then that Florida retailer is choosing to deliver the product to California or New York. That's a little bit different.

So some allow that service and take those, you know, take those arguments on and others will just do what they call intrastate shipping. So they'll only deliver where they have retailers in the same state as the consumer. But it's basically like a modified feeling of DTC, but it's not DTC.

Jessie Ott (28:05.614)
So if I had a distillery in Florida and I wanted to ship you some bottles, I could put the product on Flavier or GoPuff or wherever it is and have it shipped to a local store near you to deliver it?

Ryan (28:21.448)
No, well GoFauf is a retailer in a lot of states, so let's use, you know, and I don't want to single out Flaviar and I don't necessarily...

Jessie Ott (28:29.6)
Right, I'm just, that's one I know.

Ryan (28:31.84)
But yeah, so, know, whatever third party provider, basically what happens is the distillery or the brand still has to go through a wholesale or a sell to that Florida retailer. Right. So I go to the thirsty Thursdays, whiskey.com. I click buy now. Now that takes me to a.

Jessie Ott (28:46.945)
Okay.

Ryan (28:57.484)
or website that's managed by Thirsty Thursdays. The order then gets processed and the payment goes to a retailer in Florida who a wholesaler sold to. And now that floor retailer is selling to me and delivering to my office in Florida through the three tier system. So it's really not a DTC sale. From the consumer perspective, they'd be like, yeah, maybe I'm buying from the brand, but they're not.

buying from a liquor store up the street. It's sort of like what Drizzly used to do when it was around. Drizzly was lot of obviously a little bit different where you were seeing the inventory at different liquor stores. It's sort of like that, but the face of it is the brand face. That's kind of maybe a way to think about it.

Jessie Ott (29:28.206)
They're not.

Jessie Ott (29:32.856)
Yeah.

Jessie Ott (29:49.162)
Is there limitations to it then? So if I want a bottle delivered to me in Lake Mary, but it's not in central Florida, it's only in Miami.

Ryan (30:03.702)
Well, it can be limited in a few ways. It can be limited in where the product's distributed, right? So if you're only distributed in Florida, then it's a challenge to be able to send that product to all 50 states, obviously, because whether they use a title fee or not, there's some states where you simply are not supposed to ship to, right? So you're definitely limited by where the product is distributed.

Jessie Ott (30:04.514)
is

Jessie Ott (30:32.59)
Could that be a pass-through distributor example?

Ryan (30:35.732)
It could be any distributor that sells to that state. Sure. So it doesn't have to be a formal, you know, big guy, but it, it would have to be a distributor license in that state, obviously to sell through. So that's why DTC is obviously better, not only from a margin perspective, because as the brand you're like, yeah, I'm satisfying more sales because I'm doing it through, you know, the online platform, through this three tier system.

But they're not getting any more margin. If they're doing DCC, the consumer is still getting the same bottle for 40 bucks, but instead of selling it to the distributor for whatever, 20, and then the retailer taking its margin and all that, I'm selling it for 40 and I keep the margin. So DTC definitely helps the distilleries. And with distilleries not doing as well as they were previously, I think it's more important than ever to give them this margin and give them access, you know, to market access.

Jessie Ott (31:32.044)
Yeah. Okay. Yeah, that's a big difference.

Ryan (31:37.354)
Yeah, it's huge.

Jessie Ott (31:39.84)
Yeah, but you know, the law's a law. You gotta follow it.

Ryan (31:44.234)
No, for sure. Yeah, mean, you know, that's my rear.

Jessie Ott (31:50.582)
It's why we're here. So what, what else do we need to do? What's next in the, in the line? Did we kind of cover the Bev alcohol, the whiskey?

Ryan (32:02.72)
On the distilled spirit side, that's kind of it. And then you're just going to get more and more advanced in terms of, you know, marketing activations and what you can and cannot give to retail like that and all that kind of stuff. The regulations are very different state to state are the most restrictive for beverage alcohol. And so we spend obviously a lot of our time answering questions like we want to have an event and do this. We want to have a sponsorship. We want to, you know.

Jessie Ott (32:12.813)
Yeah.

Ryan (32:28.876)
Can we give glassware in this state versus that state? All those things are regulated. So those questions will come up. And then certainly there may be questions around like fundraising or bringing on another partner, stuff like that. And we can address all that.

Jessie Ott (32:42.7)
Yeah. Well, we got in trouble with the law. I was working at Kexy, is a tech platform, but we were at Techstars in Tulsa, Oklahoma. And we were at the last day of the three month program or six month program. And everybody that has a brand does their pitch.

And so they have tons of investors and different people coming in, listening to the pitches. And so we wanted a cool table. So I got 50 mls and put them all out with some pins and all the things come to find out there were cops there and they made us put it away. Oopsie. Yep.

Ryan (33:26.22)
Yeah, Yeah, things like that. You'd think it's like, here it's a 50 ml, but you know, how'd you get it into the state and all that kind of stuff. So it's definitely a challenge to make sure you're doing everything right.

Jessie Ott (33:41.25)
Yeah. Do you want to switch over to the, like a non-alcoholic beverage? Because I feel like, I was just going to say, I feel like from that perspective, and maybe I'm wrong, that's more of, you got to be, you know, be careful of your ingredients, where you're sourcing from, careful what, you know, verbiage you put on the can, that kind of thing.

Ryan (33:41.824)
That's why we're here.

Ryan (33:45.568)
So now, yeah, go ahead.

Ryan (34:05.696)
Yeah, it's definitely much easier, but very similar. Obviously, the good part of the TTB side with formulas and labels is that TTB approves those things. So you sort of know I did it right or it's approved, you know.

And if it was approved by TTB and error, at least I feel comfortable like, yeah, it's approved by somebody, right? On the non-oxide, FDA does not pre-approve. So you just need to make sure you get it right. And if there was an issue or is an issue, then you're going to find out through enforcement, which is very minimal, or a consumer lawsuit, which is not great. Which is not to say there can't be a lawsuit. In the beverage world, there are. I mean, in the alcohol beverage world, there are, but...

Jessie Ott (34:45.454)
Yeah, that's not great.

Ryan (34:52.352)
You know, just need to be careful because there's no pre-approval process. But it's the same thing in terms of starting the company, doing the trademarks, obviously a different class, you know, a trademark. And the co-pack agreement, you're more likely than not with non-ALC to not start your facility in co-pack somewhere. And then you're right, you want to have your label reviewed by somebody that knows what's going on in terms of the...

ingredients going into it and then the label itself, you still have those same copac agreement issues where you want to make sure that, and it's almost in some ways more, not more important, equally important, but like definitely something to think about because with alcohol, the alcohol typically is more stable for a longer period because of the alcohol. With non-alc,

there's not the same shelf life oftentimes, and there's oftentimes more issues with the product kind of going bad or getting gross. So you do want to make sure that you have your agreements reviewed. And then otherwise it's quite similar. The distributor would be more likely than not like channel related. So if you have a non-alch beer, maybe you go with a beer distributor.

If you have a non-alch spirit, maybe you go with spirits distributors. The thing is they send you largely the same contract. So it's almost like the same thing, even though you're normally not going to be locked into franchise laws or locked into a distributor contract like you might be in the out world. You kind of are by virtue of the contracts that they send you. So you just need to be careful.

Jessie Ott (36:35.554)
Yeah. Yeah. And when I think of ingredients, you know, I had Fresh Victor on earlier this year and, you know, he made a comment about how his contracts are long term with his citrus providers and this, that and the other. In other words, he's protected it kind of against these any kind of rise in prices and whatnot. And I feel I felt like, wow, that's really good advice because you never know when that could happen. Right.

Ryan (37:05.536)
Yeah, I mean, certainly if you can get a supply agreement or something with important suppliers, that's great, especially if you can lock in pricing. I've been for many years, even before the current tariff situation, putting in a provision, like sometimes distribution contracts will say,

you won't increase price for the first year or the first three years, but I'll put things like, you know, other than if our cost of goods or tariffs or things like that increases significantly, which we know you kind of define. I was doing it actually more because of agave shortages and agave pricing where if we needed to increase pricing on tequila,

we could, but it obviously becomes applicable in today's environment too. So yeah, no, it's a great idea to lock in contracts if you can, as long as you can get out if you want to. That was the whole thing with whiskey is a lot of people were getting into contracts for whiskey thinking they're gonna need it and the prices were gonna continue to skyrocket, but then lo and behold prices have gone down and the...

Market is not what it was and maybe sales aren't what they were. So now you're like, I don't even need this whiskey anymore. So you want to make sure you're not obligated to buy a bunch of juice that you don't actually even need.

Jessie Ott (38:22.368)
Yeah, yeah, for sure. Yeah, unless you just want it for home use, home consumption use.

Ryan (38:28.826)
Yeah, yeah, yeah.

Jessie Ott (38:33.336)
So did we cover the non-ELK piece?

Ryan (38:36.076)
Yeah, I mean, think Grand Alcazola is almost the same with some nuances, obviously, in terms of labeling. And there's a lot of great resources and new brands starting, so we can certainly help on that. But yeah, it's quite similar, other than the labeling requirements in terms of the path.

Jessie Ott (38:57.464)
Do you have any ex- sorry, what?

Ryan (39:00.588)
I'm saying all of them are kind of the same in terms of like, you know, getting the formation done, the trademarks done, the contract with your various suppliers and providers, et cetera.

Jessie Ott (39:12.546)
Do you have an example of a lawsuit that you want to talk about that kind of, if they had had a real lawyer look at the contract, maybe that wouldn't have happened? Like an example in your mind?

Ryan (39:27.308)
I mean, a lot of them...

A lot of them settle, right? I the ones that we're involved with are typically to get to the point where lawsuits are not actually filed. Occasionally there'll be a lawsuit filed, but more, I'm not a litigator. I mean, obviously I have litigation and courtroom experience, but we're not like a litigation firm.

But we almost always, even when we bring in litigation counsel, settle them. Like they typically don't go to trial just because the economics of trial are so high. at the end of the day, if it's even if it's like a hundred thousand dollars or $200,000, like those things typically will settle just because of the cost of litigation is so high.

Jessie Ott (40:14.124)
Yeah, no, I get that for sure. Because it could go on forever.

Ryan (40:20.596)
It's those labeling, like the poppy lawsuit, or there was the one with, I can't remember the ice cream brand with vanilla, where there's no real vanilla. Those are the ones where you need to be careful. Don't call your product vanilla ice cream if there's no vanilla, right? Things like that. Make sure it is what it is and don't mislabel products. So it's like those mislabeling or...

trying to cause confusion in the consumer's mind by saying that it is something when it's not, I would be very careful about those things.

Jessie Ott (40:53.014)
Yeah, I think you used an example of ginger on a can where they're saying, because we have ginger, it's a health benefit, right?

Ryan (41:01.868)
Totally. mean, you definitely want to be very careful of any health claims for sure. You know, like with CBD as an example, there were all those brands that were like, well, it'll cure cancer, that, you know, it'll help you do this, it'll help you do that. Like you want to be very sure that you're not making especially drug claims. One thing I was going to mention though is ADA compliance. are...

and have been over the years lawsuits for, they oftentimes target celebrity brands, but it could be anybody where they'll be a plaintiff suit and they'll sue the brand because it doesn't have the ADA compliant software on it. And it's pretty inexpensive to get that software like on your website. And it saves you, know, all of these typically settle regardless of whether the suits are, you know.

frivolous or have merit or not, they typically settle in somewhere like 10 to 20 or so thousand dollars. But I would suggest that people look into and talk to their tech providers or whoever they think is the best resource to do that.

Jessie Ott (42:17.422)
And what is it?

Ryan (42:19.454)
have you ever seen like in the bottom corner of a website, there's like the blue circle with like the white figure so that it will read the website to you. It's like an American disabilities act icon. So it does that. Yeah. Yeah. So you'll see it on some websites. It's especially material for websites that allow people to, that would otherwise be stores where you like can come in and buy stuff.

Jessie Ott (42:32.216)
Gotcha, okay.

Wow, I didn't know that.

Ryan (42:47.466)
So you'll probably start seeing it.

Jessie Ott (42:50.486)
Okay. That's a good tip. Yeah. 20, 30 grand. That's no joke.

Ryan (42:56.426)
Yeah, and it's just a few hundred bucks a year for some of them. For most of them, it's not very expensive. For the software, it's pretty easy.

Jessie Ott (43:04.974)
Okay. Do you want to move over to THC and CBD?

Ryan (43:09.984)
Sure. So quite similar. They're both relying upon the farm bill. CBD was obviously a big craze previously. I would say hemp derived THC is the latest craze and there's a difference between hemp derived THC and marijuana derived THC. Like a very big difference in terms of the laws and what's happening in the environment now. So,

Marijuana derived THC has to be sold at dispensaries, whether that's like adult use or, you know, adult use meaning recreational or medical, right? But at a dispensary. Whereas hemp derived THC is what you see now that's sold at like, sometimes I think Total Wine or like, and there's a plum market near me that sells them. And those are the ones that are like super hot right now.

But you see like almost every day different states taking actions to try to potentially close that loophole, because it is arguably a loophole. It's basically the hemp plant, hemp that's permissible under the farm bill, and they synthesize it in a way to pull out THC. So if people are going to jump on that bag wagon, perhaps the time is now.

my suggestion that people do it or not do it, but the loophole could be closed in any state at any time. Largely, obviously, you just have to keep an eye on the legislation and regulations. Just be mindful of what's going on in your state before you jump into it or the states are planning to sell to.

Jessie Ott (44:54.764)
Yeah. Yeah, boy, that's a gamble, isn't it? I know some people who were doing great with it. And from one reason or another, because, you know, Whole Foods and Sprouts, they are very particular about the ingredients that you can put in on top of just trying to maintain the THC and CBD regulations. It's almost impossible to do without a lawyer. you know, especially the way it changes all the time.

I mean, obviously there's more and more people coming into the space. So it's not like there's a lack of products or anything or people are dropping out, but it may be, you know, survival of the fittest in the sense where, may the strong survive because it is, it is hard for a small business in general, let alone to try to keep up with all these laws, these changes.

Ryan (45:48.096)
Yeah. I mean, and I think that there's just, it's a little bit of the wild west in terms of the state laws and and obviously the lack of federal laws other than, under the farm bill. So certainly people just need to kind of be on top of it and know what they're doing, but there's just so many products jumping into this space that you're right. It was sort of like the CBD craze was several years ago. It's, you know, it's just hard to know who's going to shake out as being kind of the leaders.

Jessie Ott (46:18.188)
Yeah. And it'll be interesting too, because, you know, if states are selling it and they're in the state and they reverse their policy on it, are they going to just throw all the product away? they going to pay for it and dump it?

Ryan (46:30.316)
No, I think that it would be something like where there's a sunset, right? Like the law becomes effective as of whatever. And, you know, as of January 1st, 2026, there's no more sales or, whatever, something like that. So I wouldn't have that.

Jessie Ott (46:39.638)
Yeah, dear grandfathered in.

Jessie Ott (46:47.864)
Yeah.

Ryan (46:50.06)
I think they'll be kind of like a period of time where you can wind down or transition or know what you're going to do. I don't think it's going to be like tomorrow you can't sell anymore in your entire life.

Jessie Ott (46:59.694)
So you feel like there are more states that are trying to stop it than just allow it?

Ryan (47:09.578)
Well, they're just looking at what the regulations are to either regulate it more or perhaps prohibit it, or restrict where it's sold, things like that. So it's become so popular that where maybe there wasn't anything on the books and it was sort of this gray area and people were taking advantage of that. Now states are looking at it and should we have something or should we not? But it's just a question of like now regulators are.

looking at the category because of the growth and deciding in some cases, you know, should we have something, should we not.

Jessie Ott (47:45.154)
Yeah, interesting.

Ryan (47:46.836)
and know, legislative sessions are, know, bills have been passed and nothing happened with them. So, you know, maybe we'll see what happens.

Jessie Ott (47:57.858)
Yeah.

From your perspective of these non-ELKs and CBD THCs, I feel like the wholesalers association got on board with this years ago. And so I feel like from a spirits perspective of the traditional distribution channels, they were excited about it, got in front of it. I don't know about the beer side.

And I don't know if they're as excited about it as the spirits side and or which distribution channels they're going through. Do you have any insight into that?

Ryan (48:44.202)
A little bit, I mean, we've done contracts with distributors on the CBD and hemp derived THC side. I guess there's two pieces to it. One is in the state that you're gonna distribute in, can the distributor sell things that are not beer, wine, or spirits, depending on their license, are they allowed to, right? And...

So that's one piece, is it the same distributor and can they? Assuming they can, the other question for the brand is where do you want your product? So am I competing with beer? Am I competing with like, you know, other adult soft drink type things? You know, other adult non-alcoholic beverages, presumably VR, or maybe you want to be competing with, you know, wine or, you know, whatever. I don't know what it is, but.

That's kind of how you want to determine it is where you want your product to go because different distributors have different expertise. Like the high end spirits guys are not necessarily going to C stores. If you want to be in C stores, then you find a distributor going to those stores. And maybe it's in ALC-1 or maybe it's not.

Jessie Ott (49:54.498)
Yeah, fair point. Cause I know there's... go ahead. was just, there's a... Please go.

Ryan (49:57.076)
I often. Yeah,

Ryan (50:04.468)
I would just say sometimes people ask how you know what distributor to go to. I always, and again, I don't know if this is the right way to do it or not, but I think you start backwards, meaning go to like the five or 10 accounts that you want to be in and ask who their favorite distributors are and who they order from regularly and why. And then think about talking to those folks.

Jessie Ott (50:28.462)
That's a great idea. I never thought about that.

Leave it to the smart lawyer. That's awesome. Yeah, that's a fantastic idea actually. I wonder how many accounts would say the same name. Yeah.

Ryan (50:45.078)
Well, that's yeah, right. mean, that's the question. If they do, then I think you've got a great distributor in mind. If not, then yeah, it's going to be a little bit more.

Jessie Ott (50:54.348)
Yeah. Yeah. And it really does depend on your distribution strategy. You know, if you are C-Store, it's then yeah, of course, beer is the way to go. I mean, we're kind of in that space with sake, right? Because it's really a traditional brew. and a lot of, you know, sake's are distributed through breweries or through the beer distribution channels. And, I think it's both. I think you just have to find the one that works.

for whatever your concept is, you know? And what you're kind of looking for, yeah.

Ryan (51:27.488)
Yeah, no for sure.

Jessie Ott (51:31.904)
All right. Well, I feel like we've covered quite a bit. Is there any other advice or anything else that we might have glossed over that you want to talk to talk about?

Ryan (51:41.322)
No, I think we hit it. Yeah. Now we know how to start Thirsty Thursdays. Beer, wine, spirits, non-algae, THC and CBD.

Jessie Ott (51:44.899)
Yeah.

Jessie Ott (51:52.558)
There you go. There you go. Just get a good lawyer. That's, that's really the important part. mean, and, and when like for me, I'll be honest, like we have a friend that's a lawyer and she does all of my stuff and I drive her crazy. but, without even coming up with the name of a company, I don't, I don't even, I just say, Hey, is this available? You know what I mean? Like, I feel like a lawyer is the first thing you do.

Ryan (52:23.88)
Well, it's one of the first for sure. You could certainly go on the USPTO site and type in your name. You can do Google searches. You can go on TTB's website if it's an app product and see if anybody else is using the name on another label. So that's a good way to kind of cut down your list. And then when you come up with like one or two that you like or whatever, then...

then maybe reach out to a trademark lawyer or a lawyer who does trademarks on a regular basis and you'll run the clearance searches then just to save some time.

Jessie Ott (52:57.996)
Yeah. One of the things I remember you mentioning back to Thursday Thursday's whiskey was, you have to, you said, mentioned something about getting a permit in the state. And is that a time consuming thing to do or to get?

Ryan (53:17.172)
Yeah, I mean, it can be in some states. It's not so bad other states. It can be longer. so basically federally, you need a permit, obviously, to be able to buy and sell alcohol at the wholesale level. And then in your state, you're more likely than not going to need some sort of permit to be able to do the same. It's not always a wholesale permit. Some states have a different permit that you would get, but usually it's a couple of months.

There's some states that are much, longer and some states that are shorter. And then the other thing just to be mindful of, if you are doing these things yourself and not using kind of one of these compliance companies we talked about in terms of the, outside, you are going to need in a lot of states, various permits to sell to distributors in that other state, you know, out of state shipper type permits. Not all states have that requirement, but

Some do. And so, you know, just be mindful of that when you're going into new state, there may be a delay because you need a permit to sell to that distributor in some cases, or like the case of New York. Yeah, or like in New York, you have a price posting. you know, someone's like, I want to start selling June 1st. And it's already, you know, May, you know, the middle of May. It's like, well, you're a little late for that, but you just be mindful of kind of backing into the date you want to start and the permits needed, if any.

Jessie Ott (54:20.247)
I didn't know that.

Jessie Ott (54:39.576)
So how long do you have to have your price within the system to start selling? How long does it take?

Ryan (54:44.62)
So you price those things monthly in New York and so you would price post basically for like the next month, right? So like in May you would price post for July basically. But there's a schedule on their SLA website that's, mean, SLA has a great website that.

Jessie Ott (54:55.435)
Okay.

Jessie Ott (55:04.09)
very cool. Yeah. See, every state is different. makes it so crazy. And it's so funny because we're doing it. I have an export business now and we're trying to learn each of these different countries. when the more I talk to people, you know, on the podcast, they're like, it's literally from going from one state to the next, it's literally like working in a different country because the laws are so different.

Ryan (55:27.372)
Yeah, it definitely can be, which is it's fun for us. So, all good.

Jessie Ott (55:33.782)
Yeah, keeps Ryan busy. Awesome. Well, I thank you for coming on. How do people get in touch with you?

Ryan (55:37.044)
Yeah.

Ryan (55:44.95)
Sure, my website is malkin.law, M-A-L-K-I-N dot L-A-W. And we have LinkedIn and Instagram, you know, at Malkin Law. So yeah, feel free to follow us on both and shoot an email over and let me know if I can help.

Jessie Ott (56:05.566)
Awesome. Awesome. Awesome. Awesome. Well, I like to play a little game at the end if you're game for it, where it's kind of rapid fire questions. So if I were to ask you, what kind of drink would you be? Whether it's alcohol, non-alcohol, doesn't matter.

Ryan (56:13.664)
Diego.

Ryan (56:32.418)
that's the question.

Jessie Ott (56:34.102)
Yeah, that's the question. Sorry. What kind of cocktail is Ryan Milken?

Ryan (56:39.917)
yeah, I would probably say maybe a Negroni.

Jessie Ott (56:46.134)
Nice. Nice. Negronies are great. They're fun to make too.

Ryan (56:52.33)
Yeah, they're fun to make and yeah, those are typically my go-to at restaurants.

Jessie Ott (56:59.318)
Nice. That's a good one. What about, what's, what's your favorite movie?

Ryan (57:08.448)
Well, the one I can watch over and over and never get bored of it is the Big Lebowski.

Jessie Ott (57:13.87)
that's a good one. That's a good one. Towards the end of COVID, there was a movie theater that played it and I had a little sponsorship going on with Terra Mana. We watched it in a big movie theater. It was so fun.

Ryan (57:27.198)
great. It never gets old, that one.

Jessie Ott (57:31.054)
It doesn't. So is there any lines from that movie or any other movie that you like to say?

Ryan (57:40.045)
not nothing I typically say from a movie that comes to mind. Unfortunately, I'm sure as soon as we get off, I'll come up with something.

Jessie Ott (57:51.83)
Yeah, that's okay. What about...

Ryan (57:54.604)
I mean, as, it relates to their podcast, and the industry, guess, you know, there's a beverage here is always a good one, you know, when he's holding the cocktail, getting out of the car. so, you know, I guess we'll go with that. Yeah. Yeah. I guess we'll go with that one.

Jessie Ott (58:07.629)
Yeah.

White Russian, right? Yeah. What about favorite food?

Ryan (58:19.436)
I love Italian and Mexican. Eat sushi a lot. mean, you know, those are probably the... Yeah, yeah, yeah.

Jessie Ott (58:28.718)
Food, you like food? There's nothing that's your go-to?

Ryan (58:34.238)
I would say Italian when I'm in Detroit area, middle Eastern often, cause they have great middle Eastern, especially in the Detroit area when I go home. you know, so if I'm traveling, I try to do something local.

Jessie Ott (58:40.946)
yeah.

Jessie Ott (58:48.758)
Yeah, no, 100%. I love that too. That's what the whole traveling experience is about.

Ryan (58:58.016)
Yeah.

Jessie Ott (58:59.714)
You know, much like the laws, the people and the food can vary too. Hopefully, right? Hopefully there's some local dishes and local customs that are important to keep.

Ryan (59:04.896)
Mm-hmm.

Ryan (59:08.425)
Exactly.

Exactly.

Ryan (59:16.108)
for sure.

Jessie Ott (59:18.466)
Well, Ryan, this has been really fun and very informational. Ryan and I have talked about putting this in paper or on a website so that we, it's like a downloadable, cheat sheet, if you will, for these different segments that you might be interested in, you know, building a brand that, you know, might be a little, might be helpful along your, your journey and, creating a brand. And then of course you'll have Ryan at, at.

at your fingertips because he can help you along the way as well as set the bar. Set the bar is a great resource if you're, you know, in a state you're not familiar with or getting to know that's a good place to go to get all the laws and all the explanations behind it. So that's awesome. Any, any last words, Ryan?

Ryan (01:00:14.508)
I don't think so. Thank you for having me. I appreciate it.

Jessie Ott (01:00:18.572)
Yeah, of course. Thank you for coming on. I really appreciate you coming on and taking the time out to do the podcast with me.

All right. Take care, Ryan. Bye. You're so stoic.

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