November 26, 2024

Joseph F. Basile III
Chief Executive Officer
JFB Construction Holdings
1300 S. Dixie Highway, Suite B
Lantana, FL 33462

        Re: JFB Construction Holdings
            Registration Statement on Form S-1
            Filed November 8, 2024
            File No. 333-283106
Dear Joseph F. Basile III:

        We have reviewed 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. Unless
we note
otherwise, any references to prior comments are to comments in our October 28,
2024 letter.

Registration Statement on Form S-1
Report of Independent Registered Public Accounting Firm, page F-2

1.     We note changes to the audited financial statements and your notes to
the audited
       financial statements subsequent to the date of the audit report. Please
tell us how your
       auditor determined it was unnecessary to provide an updated audit
report.
       Alternatively, please amend your filing to include an updated audit
report from your
       auditor. Refer to PCAOB AS 3110.
Note 4 - Business Segment Information, page F-11

2.     We note your response to prior comment 7 and your expanded segment
       disclosure. Please address the following:
           Please tell us how your segment disclosure complies with the
disclosure
           requirements pursuant to ASC 280-10-50-22 through 50-26;
 November 26, 2024
Page 2

             Please tell us your consideration for providing disclosures
required by ASC 280-
           10-50-29, including an explanation of the measurements of segment
profit or loss
           and segment assets for each reportable segment; and
             Please provide reconciliations of total reportable segments
measure of profit or
           loss to your consolidated net income before taxes and of total
reportable
           segments    assets to your consolidated assets. Refer to ASC
280-10-50-30(b) and
           (c).

        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 Kellie Kim at 202-551-3129 or Isaac Esquivel at
202-551-3395 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Catherine De Lorenzo at 202-551-3772 or Dorrie Yale at 202-551-8776
with any
other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Real
Estate & Construction
cc:   Gina Austin, Esq.