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                              May 23, 2024

       Gilberto Tomazoni
       Chief Executive Officer
       JBS S.A.
       Av. Marginal Direita do Tiet   500, Bloco I, 3rd Floor
       CEP 05118-100
       S  o Paulo, SP, Brazil

                                                        Re: JBS S.A.
                                                            Registration
Statement on Form F-4
                                                            Filed March 27,
2024
                                                            File No. 333-278254

       Dear Gilberto Tomazoni:

              We have conducted a limited review of your registration statement
and have the
       following comments.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.

       Form F-4 filed March 27, 2024

       General

   1.                                                   We note disclosure that
your ADS program will be terminated prior to completion of the
                                                        corporate
restructuring. Please revise to reflect that the ADS program will not be
                                                        terminated until after
completion of the corporate restructuring and all ADSs have been
                                                        exchanged, if true.
Additionally revise disclosure on page 4 to clarify that only Eligible
                                                        Shareholders are
entitled to convert Class A shares to Class B shares during the
                                                        conversion period.
   2.                                                   To the extent that the
comments contained in our letter dated May 23, 2024, relating to the
                                                        Form F-4 filed by JBS
B.V. (File No. 333-273211) apply to the disclosure contained in
                                                        this filing, please
make appropriate and corresponding revisions.
 Gilberto Tomazoni
FirstName
JBS S.A. LastNameGilberto Tomazoni
Comapany
May        NameJBS S.A.
     23, 2024
May 23,
Page 2 2024 Page 2
FirstName LastName
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Beverly Singleton at 202-551-3328 or Claire Erlanger at
202-551-3301 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jennifer Angelini at 202-551-3047 or Geoffrey Kruczek at 202-551-3641
with any other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of
Manufacturing
cc:      John Vetterli