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                             June 14, 2022

       James Cacioppo
       Chairman and Chief Executive Officer
       Jushi Holdings Inc.
       301 Yamato Road, Suite 3250
       Boca Raton, FL 33431

                                                        Re: Jushi Holdings Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted May 17,
2022
                                                            CIK No. 0001909747

       Dear Mr. Cacioppo:

              We have reviewed your 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.

       Draft Registration Statement on Form S-1 filed May 17, 2022

       Prospectus Summary
       Recent Developments, page 8

   1.                                                   Please revise here to
disclose any negative covenants entered into in connection with the
                                                        Acquisition Facility.
       Risk Factors
       We have a substantial level of indebtedness, and we may not be able to
generate sufficient cash
       to service all of our indebtedness..., page 20

   2.                                                   Please quantify your
debt service cost for your 10% Senior Secured Notes and Acquisition
                                                        Facility and what
assets have been pledged to secure the indebtedness.
 James Cacioppo
Jushi Holdings Inc.
June 14, 2022
Page 2
Capitalization, page 33

3.       Since the amount of your cash and cash equivalents is not part of your
capitalization,
         please revise to present separate and distinct totals for cash and
cash equivalents and for
         your capitalization. Please do not combine the amount of cash and cash
equivalents in the
         total amount for your capitalization.
Business, page 50

4.       We note your disclosure on page 53 that you intend to utilize
intellectual property related
         to your cannabis brands. Please revise your Business section to
disclose the intellectual
         property rights you have obtained and whether you intend to file for
additional rights.
         Refer to Item 101(c)(1)(iii)(B) of Regulation S-K.
Product Selection and Offerings, page 53

5.       Please revise here to disclose whether your CBD products are derived
from hemp
         containing no more than 0.3 percent THC. To the extent they are not,
add risk factor
         disclosure that your CBD products may violate the Controlled
Substances Act.
6.       You state on page 54 that you sell Nira products through your online
store at
         www.niracbd.com. This website no longer appears to be active. We note
previous visits to
         this webpage presented text stating the Nira CBD online store is
permanently closed.
         Please revise your disclosure or otherwise explain.
Business in Europe, page 55

7.       We note your financial statements are provided    in thousands    and
so it appears your
         impairment loss you reference on page 55 should be $4,561,000. Please
revise or
         otherwise advise.
Principal Markets & Competition, page 55

8.       Please state what MSO stands for the first time it is used.
Description of Capital Stock,Cacioppo
FirstName LastNameJames        page 101
Comapany
9.         NameJushi
       Please revise to Holdings  Inc.
                        disclose whether  the voting rights of your shares are
cumulative or non-
       cumulative. Refer
June 14, 2022 Page 2      to Instruction 1.A of Item 202 of Regulation S-K.
FirstName LastName
 James Cacioppo
FirstName  LastNameJames Cacioppo
Jushi Holdings Inc.
Comapany
June       NameJushi Holdings Inc.
     14, 2022
June 14,
Page  3 2022 Page 3
FirstName LastName
Other Important Provisions in our Articles, page 106

10.      We note your disclosure here that the courts of the province of
British Columbia and
         appellate courts therefrom shall be the sole and exclusive forum for
certain proceedings.
         Please revise this section to disclose how this provision will be
applied to claims brought
         under the Securities Act and the Exchange Act; address any uncertainty
about
         enforceability; and, to the extent that the provision applies to
claims under the federal
         securities laws, include risk factor disclosure.
       You may contact Julie Sherman at 202-551-3640 or Kevin Kuhar at
202-551-3662 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Daniel Crawford at 202-551-7767 or Christopher Edwards at 202-551-6761
with any
other questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of Life
Sciences
cc:      W. Stuart Ogg, Esq.