May 1, 2019

Kevin Berryman
Chief Financial Officer
Jacobs Engineering Group, Inc.
1999 Bryan Street, Suite 1200
Dallas, Texas 75201

       Re: Jacobs Engineering Group, Inc.
           Form 10-K For the Fiscal Year Ended September 28, 2018
           Filed November 21, 2018
           File No. 001-07463

Dear Mr. Berryman:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

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

Form 10-K For the Fiscal Year Ended September 28, 2018

2. Significant Accounting Policies
Contractual Guarantees, Litigation, Investigations and Insurance, page F-13

1.    With reference to ASC 460-10-30 and, if material, please disclose your
accounting for
      guarantees. Expand your disclosure herein or Note 15 to provide all the
disclosures
      required by ASC 460-10-50-2 through 4, including the maximum potential
amount of
      future payments as required by ASC 460-10-50-4b.
5. Business Combinations, page F-20

2.    We note that the CH2M purchase price allocation includes approximately
$385.3 million
      related to provisional estimates related to various legal and other
pre-acquisition
      contingent liabilities accounted for under ASC 450. It appears that
$364.4 million of this
      amount appears to relates to measurement period adjustments made in the
fourth quarter
      of fiscal 2018. Please tell and expand your disclosures to discuss the
facts and
 Kevin Berryman
Jacobs Engineering Group, Inc.
May 1, 2019
Page 2
         circumstances that lead to this adjustment. In this regard, we note
that the disclosures
         surrounding CH2M's contingencies that were provided in the period of
acquisition are
         essentially the same as your current disclosures in Note 15, including
your conclusion that
         these contingencies are not expected to be material. Finally, to the
extent known, please
         explain why CH2M did not appear to have an accrual recorded related to
these
         contingencies as of the acquisition date.
13. Income Taxes, page F-37

3.       We note that your valuation allowance increased $206.8 million from
September 29, 2017
         to September 28, 2018, of which $104.2 million related to certain
foreign tax credits and
         resulted in an increase to your provision for income taxes. Please
explain the remaining
         $102.6 million increase to your valuation allowance and how that
increase was reflected
         in your financial statements. In addition, please explain why your
acquisition of CH2M
         impacted your unrecognized tax benefits rather than your deferred tax
assets and
         liabilities. Furthermore, please reconcile your $179.1 million
unrecognized tax benefits as
         of September 28, 2108 as presented in your tabular presentation to
your textual disclosure
         which indicates that your gross unrecognized tax benefits was $76.7
million. To the
         extent that this $102.4 million difference relates to the change in
your valuation
         allowance, please explain your accounting. Please provide the
authoritative literature you
         relied on.
       In closing, 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.

       You may contact Ernest Greene, Staff Accountant at 202-551-3733 or
Jeanne Baker,
Staff Accountant at 202-551-3691 with any questions.



                                                              Sincerely,
FirstName LastNameKevin Berryman
                                                              Division of
Corporation Finance
Comapany NameJacobs Engineering Group, Inc.
                                                              Office of
Manufacturing and
May 1, 2019 Page 2                                            Construction
FirstName LastName