July 10, 2024

Matthew Shafer
Chief Financial Officer
Cardiff Lexington Corp
3753 Howard Hughes Parkway, Suite 200
Las Vegas, NV 89169

       Re: Cardiff Lexington Corp
           Form 10-K for Fiscal Year Ended December 31, 2023
           Filed March 27, 2024
           File No. 000-49709
Dear Matthew Shafer:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for Fiscal Year Ended December 31, 2023
1. Summary of Significant Accounting Policies
Accounts Receivable, page F-9

1.     We note that as of December 31, 2023, the accounts receivable-net
balance is
       $13,305,254 compared to total revenue of $11,853,266 for fiscal year
2023. Please
       address the following:
           Comprehensively explain why the accounts receivable-net year-end
balance increased
          $6,701,334, or 101.5%, compared to the revenue increase of
$1,160,070, or 10.8%.
          Also, with reference to the $2,661,966 revenue recognized for the
first quarter of
          fiscal year 2024, explain why the year-end account receivable-net
balance increased
          by $1,344,676 to $14,649,930.
           Address how you concluded that the accounts receivable-net balance
is collectible as
          of December 31, 2023 and March 31, 2024. As part of your response,
tell us which
          method you used to measure expected credit losses for your accounts
receivable-net
          and how much of the balance has been collected to date.
 July 10, 2024
Page 2

             Provide us with an aging of your accounts receivables as of
December 31, 2023, and
           March 31, 2024.
             Confirm that you will provide expanded MD&A disclosures to provide
a
           comprehensive discussion of the reasons underlying changes in your
accounts
           receivable-net balances for each period presented as well as a
comprehensive analysis
           of the collectability of these balances. This discussion should
address any material
           aging of your account balances. Refer to Item 303(b)(1) of
Regulation S-K,
           Instruction 4 of Item 303(b) of Regulation S-K and Section 501.13.
of the Financial
           Reporting Codification (i.e., Release 33-8350, Section IV.).
             Tell us how you concluded that it was probable you would collect
substantially all the
           consideration you were entitled to under your customer contracts.
Refer to ASC 606-
           10-25-1.e. and ASC 606-10-25-5 through 25-7.
             Tell us the significant payment terms and confirm that you will
provide this
           disclosure in accordance with ASC 606-10-50-12.b.
             Provide us with a rollforward of the allowance for credit losses
for each period
           prepared in accordance with ASC 326-20-50-13 and confirm that you
will provide
           this disclosure along with the disclosures required by ASC
326-20-50-11 and ASC
           326-20-50-17.


       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.

       Please contact Tracey Houser at 202-551-3736 or Jeanne Baker at
202-551-3691 with any
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services