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                          November 19, 2021

       Carol Craig
       Chief Executive Officer
       Sidus Space, Inc.
       150 N. Sykes Creek Parkway, Suite 200
       Merritt Island, FL 32953

                                                        Re: Sidus Space, Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted November
10, 2021
                                                            CIK No. 0001879726

       Dear Ms. Craig:

             We have reviewed your amended draft registration statement and
have the following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments. References to prior comments refer to comments in our October
25, 2021 letter.

       Amendment No. 1 to DRS on Form S-1 submitted November 10, 2021

       Cover Page

   1.                                                   We note your response
to prior comment 1. Please expand your disclosure on the cover
                                                        page to include the
identity and beneficial ownership percentage of your controlling
                                                        shareholder and provide
a cross-reference to a longer discussion of the exemptions
                                                        available to you, and
those on which you intend to rely, as a "controlled company."
 Carol Craig
FirstName  LastNameCarol   Craig
Sidus Space, Inc.
Comapany 19,
November   NameSidus
               2021 Space, Inc.
November
Page 2     19, 2021 Page 2
FirstName LastName
Prospectus Summary, page 1

2.       We note your revised disclosures include a list of various
manufacturing contracts and
         significant milestones. Please further revise to disclose the fiscal
year(s) covered by each
         contract. Also, in an effort to provide a balanced discussion, revise
to disclose the total
         revenue generated for each period presented on page 1.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 39

3.       We note your revised disclosures in response to prior comment 6.
Please revise your
         results of operations discussion for the interim periods ended
September 30th to include a
         similar discussion regarding the number of customers at each period
end and the impact of
         such changes on your revenue for each period.
Exclusive Forum, page 75

4.       We note your response to prior comment 9. While you discuss a federal
exclusive forum
         provision for Securities Act and Exchange Act claims here, you do not
discuss this
         provision in the risk factor on page 33. Please revise to consistently
describe your
         exclusive forum provisions or advise.
Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies, page F-7

5.       You state in your response to prior comment 11 that you have revised
your disclosures to
         include the research and development costs charged to expense for each
period presented;
         however, no such revisions appear to have been made. Considering the
importance of your
         research and development projects on the future success of your
business, please revise to
         disclose the total research and development costs charged to expense
for each period
         presented. Refer to ASC 730-10-50-1.
Consolidated Statements of Operations, page F-15

6.       Please provide the calculations that support the Class A and Class B
per share
         information. In this regard, it is unclear how you allocated earnings
to each class of
         common stock and why per share amounts would differ for each class
given dividend
         rights are the same. Please explain further or revise your disclosures
as necessary. Refer
         to ASC 260-10-45-60B.
Consolidated Statements of Stockholder's Deficit, page F-17

7.       You disclose that in August 2021, all outstanding shares of common
stock were
         exchanged for 10 million shares of Class B common stock. Please tell
us your
         consideration to retroactively reflect such exchange for all periods
presented. Specifically
         address your consideration of the guidance in ASC 505-25-25 and SAB
Topic 4.C.
 Carol Craig
FirstName  LastNameCarol   Craig
Sidus Space, Inc.
Comapany 19,
November   NameSidus
               2021 Space, Inc.
November
Page 3     19, 2021 Page 3
FirstName LastName
General

8.       We note on page 6 and elsewhere that you removed references to an
underwriter   s over-
         allotment option. We also note, however, that other disclosures
continue to reference an
         over-allotment option. Please tell us whether your underwriter will
have an over-
         allotment option and ensure your prospectus disclosure is consistent
throughout.
        You may contact Megan Akst, Senior Staff Accountant, at (202) 551-3407
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions
regarding comments
on the financial statements and related matters. Please contact Kyle Wiley,
Staff Attorney, at
(202) 344-5791 or Mitchell Austin, Staff Attorney, at (202) 551-3574 with any
other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Technology
cc:      Jeff Fessler