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                             November 16, 2023

       Morgan Callagy
       Co-Chief Executive Officer
       Revelstone Capital Acquisition Corp.
       14350 Myford Road
       Irvine, CA 92692

                                                        Re: Revelstone Capital
Acquisition Corp.
                                                            Amendment No. 2 to
Registration Statement on Form S-4
                                                            Filed October 23,
2023
                                                            File No. 333-274049

       Dear Morgan Callagy:

            We have reviewed your amended 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.
Unless we note otherwise,
       any references to prior comments are to comments in our October 17, 2023
letter.

       Amendment No. 2 to Registration Statement on Form S-4

       The Business Combination, page 22

   1.                                                   We note your response
to prior comment 1 and your revised disclosure that any shares of
                                                        Revelstone Common Stock
issued as a result of a reduction in the amount of Closing Debt
                                                        shall not be
registered. Please tell us whether such shares will be issued pursuant to an
                                                        exemption from
registration and, if so, tell us the exemption relied upon for the issuance
                                                        and the basis for such
reliance.
       Risks Related to Revelstone, page 62

   2.                                                   We note your response
to prior comment 3 and reissue in part. Please revise your
                                                        disclosure to discuss
whether your waiver of the corporate opportunities doctrine in your
                                                        existing charter
impacted your search for an acquisition target.
 Morgan Callagy
Revelstone Capital Acquisition Corp.
November 16, 2023
Page 2
Background of the Business Combination, page 90

3.       We note your response to prior comments 6 and 7 and reissue in part.
Please provide us
         with any correspondence between Bank of America and Revelstone
relating to the firm   s
         resignation. In addition, please provide us with the engagement letter
between Revelstone
         and Bank of America. In addition, revise your filing to clarify
whether Bank of America
         performed substantially all the work to earn its fees.
Proposal No. 2 - The Charter Proposal, page 136

4.       We note your revised disclosure in this section and throughout your
filing that one of the
         proposed changes to the charter is to    eliminate the corporate
opportunity doctrine.    With
         a view toward disclosure, please tell us how the proposed change to
your charter would
         eliminate the corporate opportunity doctrine.
Certain Set Jet Relationships and Related Party Transactions, page 186

5.       We note your disclosure regarding the Select Services Agreement by and
between Set Jet
         and Sierra Delta Romeo LLC, a company controlled by Steve Reynolds,
pursuant to
         which Set Jet granted Mr. Reynolds certain rights to use the 1996
Bombardier Challenger
         850 for agreed upon rates set forth therein. We also note your
disclosure regarding the
         Select Services Agreement by and among Set Jet, N602SJ, LLC and David
Jacofsky.
         Please revise to disclose any material conflicts of interest related
to such agreements, such
         as limitations on the use of the aircraft by Set Jet when needed, if
material.
6.       We note your disclosure regarding the Amended Aircraft Charter
Agreement by and
         between Set Jet and Scottsdale Jet Charter, LLC. However, we note that
it appears that
         other aircraft used by Set Jet are also owned by related persons
within the meaning of
         Item 404 of Regulation S-K. Please provide the information set forth
in Item 404 with
         respect to such arrangements, or provide your analysis as to why such
information is not
         required.
Comparison of Stockholder Rights, page 215

7.     We note that Section 3.4 of your proposed Amended and Restated Bylaws
set forth in
       Appendix C provides that any director may be removed from office by the
stockholders of
FirstName LastNameMorgan Callagy
       the Corporation only for cause. However, this does not appear to be
consistent with your
Comapany    NameRevelstone
       disclosure on page 216Capital Acquisition
                              that directors may Corp.
                                                 be removed with or without
cause. Please
       revise.
November 16, 2023 Page 2
FirstName LastName
 Morgan Callagy
FirstName
RevelstoneLastNameMorgan    Callagy
          Capital Acquisition Corp.
Comapany 16,
November  NameRevelstone
              2023         Capital Acquisition Corp.
November
Page 3    16, 2023 Page 3
FirstName LastName
       Please contact Robert Babula at 202-551-3339 or Jenifer Gallagher at
202-551-3706 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Michael Purcell at 202-551-5351 or Laura Nicholson at 202-551-3584 with
any other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Energy &
Transportation
cc:      Alex Weniger-Araujo