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                              December 13, 2023

       Marc Fogassa
       Chief Executive Officer
       Jupiter Gold Corporation
       Rua Vereador Jo  o Alves Praes n   95-A
       Olhos D     gua , MG 39398-000 , Brazil

                                                        Re: Jupiter Gold
Corporation
                                                            Form 20-F for the
Fiscal Year ended December 31, 2022
                                                            Filed April 28,
2023
                                                            File No. 333-214872

       Dear Marc Fogassa:

                                                        We have reviewed your
filing and have the following comments.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 20-F for the Fiscal Year ended December 31, 2022

       Information on the Company, page 7

   1.                                                   We note that you have
not provided the information about your Property, Plants and
                                                        Equipment under the
heading Information on the Company, as prescribed by Item 4.D of
                                                        Form 20-F, though have
included limited details regarding your mineral properties under
                                                        Management's Discussion
and Analysis instead.

                                                        Instruction 3 to Item 4
of Form 20-F requires issuers engaged in mining operations to
                                                        provide the disclosures
outlined in Subpart 1300 of Regulation S-K. We suggest that you
                                                        reposition the mineral
property disclosures to Item 4 to provide greater clarity, focus, and
                                                        differentiation between
such property details, and the discussion and analysis that is
                                                        required by Item 5,
regarding your financial condition and results of operations.

                                                        The disclosures
pertaining to your mineral properties will need to be revised and expanded
                                                        to clearly identify and
distinguish between material properties and non material properties
                                                        to address the
requirements under Item 1303 and Item 1304 of Regulation S-K, as
                                                        referenced in Item
1301(d) of Regulation S-K.
 Marc Fogassa
FirstName
Jupiter GoldLastNameMarc
             Corporation Fogassa
Comapany13,
December    NameJupiter
               2023     Gold Corporation
December
Page  2    13, 2023 Page 2
FirstName LastName

         The summary disclosure should include a map of all properties to
comply with Item
         1303(b)(1) while the individual property disclosures should include
the following details
         for each material property to comply with Item 1304(b) of Regulation
S-K:

                a map showing the location of the property that is accurate to
within one mile using
              an easily recognizable coordinate system,
                a description of infrastructure,
                a description of the mineral rights,
                a description of the work that you have completed on each
property,
                a description of the exploration plan, including timeframe and
cost, and
                the total cost or book value of the property at the end of the
period.

         The summary disclosures should encompass all of your properties,
including both material
         and non-material properties, and should appear in advance of and
incremental to the
         individual property disclosures. The information required for the
individual property
         disclosures are more extensive and detailed in comparison.

         Please revise your filing to include and differentiate between the
summary and individual
         property disclosures to comply with the aforementioned guidance.
2.       We note your disclosures on pages 9 and 13, quantifying gold
mineralization at the Alpha
         project, and quantifying mineralization of quartzite, respectively,
notwithstanding your
         disclosure on page 6 clarifying that you have not established
reserves.

         Please remove and refrain from disclosing estimates of mineralization
that do not meet the
         resource or reserve definitions in Item 1300 of Regulation S-K, and
that you are unable to
         support in accordance with Item 1302(a)(1) of Regulation S-K.
3.       Please expand your disclosures to include the information regarding
your exploration
         program internal controls to comply with Item 1305 of Regulation S-K,
or if you have not
         established these controls, to include a clear statement to this
effect.
4.       We note that you include a picture of a gold bar on page 27 that you
indicate was obtained
         from processing materials in your plant.

         Please expand your disclosures to clarify whether such materials were
obtained from
         properties in which you have an ownership or economic interest and if
this is the case,
         also identify the particular properties involved and explain when the
material was
         recovered and how the associated costs and gold inventories or
proceeds from sales or
         gold have been recorded in your financial statements.

         However, if the gold bar is not from you own materials but is
representative of work that
         either was or is being performed at your plant for other persons,
provide further details of
         the arrangements including the relevant dates, properties and persons
involved, and
         explain how you had or are accounting for these transactions.
 Marc Fogassa
Jupiter Gold Corporation
December 13, 2023
Page 3

         Otherwise, if there is no relevant correlation with your properties or
work that is being
         performed for other persons we suggest that you either remove the
picture or include
         disclosure clarifying why you believe it is properly associated with
your plant.

        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.

       Please contact John Coleman at 202-551-3610 or Karl Hiller at
202-551-3686 if you have
questions regarding comments.



FirstName LastNameMarc Fogassa                                 Sincerely,
Comapany NameJupiter Gold Corporation
                                                               Division of
Corporation Finance
December 13, 2023 Page 3                                       Office of Energy
& Transportation
FirstName LastName