December 11, 2024

Kip Eardley
President and Principal Executive Officer
James Maritime Holdings Inc.
9160 South 300 West, #101
Sandy, UT 84070

       Re: James Maritime Holdings Inc.
           Form 10-K for Fiscal Year Ended December 31, 2023
           Amendment No. 1 to Form 10-K for Fiscal Year Ended December 31, 2023
           Form 10-Q for Quarterly Period Ended September 30, 2024
           File No. 000-21322
Dear Kip Eardley:

       We have reviewed your filings and have the following comment(s).

       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.

Amendment No. 1 to Form 10-K for Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results Of
Operations
Results of Operations
Years Ended December 31, 2023 and 2022
Cost of Revenue, page 15

1.     Your revenues increased 117% from 2022 to 2023 while your cost of goods
sold
       increased by 88%. Please provide a discussion that explains this
difference in the rate
       of growths. To the extent the increases are attributable to multiple
factors, separately
       quantify individual factors. Refer to Item 303 of Regulation S-K. This
comment also
       applies to your Form 10-Q for Quarterly Period Ended September 30, 2024.
General and Administrative, page 16

2.     Please separately quantify each of the factors attributable to the
increase in the general
       and administrative expenses. In this regard, you attribute the increase
in general and
       administrative expenses to the increase in accounting and legal expenses
and the
 December 11, 2024
Page 2

       acquisition of USS. Separately quantify these factors. Refer to Item 303
of Regulation
       S-K. This comment also applies to your Form 10-Q for Quarterly Period
Ended
       September 30, 2024.
Signatures, page 27

3.     Please ensure that your Forms 10-K are signed by the registrant, and on
behalf of the
       registrant by its principal executive officer, its principal financial
officer, its controller
       or principal accounting officer, and by at least the majority of the
board of directors.
       Any person who occupies more than one of the specified positions shall
indicate each
       capacity in which he signs the report. Refer to General Instruction D(2)
of Form 10-K.
Consolidated Statements of Operations, page F-5

4.     Please provide us with a detailed discussion of the $398,922 gain on
settlement
       recorded in fiscal year 2022 and cite the specific authoritative
accounting literature
       you utilized to support your accounting treatment.
5.     Please provide us with a detailed discussion of the $2,959,811 employee
retention
       credit recorded in fiscal year 2022 and cite the specific authoritative
accounting
       literature you utilized to support your accounting treatment.
Notes to the Consolidated Financial Statements
2. Summary of Significant Accounting Policies
Revenue Recognition, page F-11

6.     Please disclose the duration of a typical security service contract and
provide an
       analysis to support the recognition of security service revenues after
their completion,
       rather than over time. Cite the specific authoritative accounting
literature you utilized
       to support your accounting treatment.
7.     We note from your disclosure that you sell a variety of personal
protective products
       and provide security services. Please tell us your consideration of
making the
       disclosures in ASC 280-10-50-40. In addition, if you have determined
that you have a
       single reportable segment, explain the basis for your conclusion,
including a
       discussion of whether your different revenue streams represent separate
operating
       segments. If operating segments have been aggregated, please tell us the
basis for
       such aggregation and also tell us your consideration of the disclosure
requirements in
       ASC 280-10-50-21.
8.     Please disclose your disaggregation of revenue in accordance with ASC
606-10-50-5.
3. Share Exchange Agreement with United Securities Specialists, Inc. (USS),
page F-14

9.     Please tell us how you accounted for the contingent consideration and
cite the specific
       authoritative accounting literature you utilized to support your
accounting treatment.
 December 11, 2024
Page 3
8. Notes Payable, current and non-current, page F-17

10.    It appears from your disclosure on page 24 of your 10-Q for the nine
months ended
       September 30, 2024 that you entered into a promissory note agreement
with Padang
       Padang, LTD for $ 48,874 on October 21, 2023. It does not appear that
this
       promissory note agreement has been accounted for in outstanding loans at
December
       31, 2023. Please clarify or revise.
9. Loans, current and non-current, page F-18

11.    It appears from your disclosure on page 26 of your 10-Q for the nine
months ended
       September 30, 2024 that you entered into a Factoring Agreement with Bay
View
       Funding on April 13, 2023 that had an outstanding principal balance of
$398,533 at
       December 31, 2023. It does not appear that this Factoring Agreement has
been
       accounted for in outstanding loans at December 31, 2023. Please clarify
or revise.
11. Stockholders' Equity
Common Stock
c. Transactions during 2022, page F-20

12.    We note you issued 100,000 units in October 2022. Please tell us how you
accounted
       for the warrants issued with common stock and cite the specific
authoritative
       accounting literature you utilized to support your accounting treatment.
General

13.    You prominently discuss Gladiator   s operation and their strengths
throughout your
       filing as though it is an active operation. However, you do not carry
any inventories
       and you wrote off supplier relationships and customer relationships
during 2023 due
       to the uncertainty of Gladiator   s future operations. Please revise
your disclosures
       throughout your filing to reflect the current phase and the size of your
operations
       through Gladiator.
14.    On page F-14 of your 2022 Form 10-K, you state that    in the event
Gladiator   s
       revenues and EBITDA percentage does not equal or exceed $2,000,000 and
25%,
       respectively, during any consecutive twelve-month period commencing on
the closing
       date and ending on the 24-month anniversary of the Closing date, the
seller   s
       shareholders shall return to the Company an aggregate of 500,000 shares
of James
       Maritime common stock. Please tell us whether you have received or will
receive
       these shares and, if so, how you accounted or will account for them.
Cite the specific
       authoritative accounting literature you utilized to support your
accounting treatment.
 December 11, 2024
Page 4
Form 10-Q for Quarterly Period Ended September 30, 2024
Consolidated Statements of Operations and Comprehensive Loss, page 6

15.    Please tell us why you do not allocate any loss to non-controlling
interest for the
       nine months ended September 30, 2024.
16.    We note the your recorded $1,091,374 in PPP loan forgiveness. Please
tell us where
       the liability is recorded and when the original loan was issued.
Notes to Unaudited Condensed Consolidated Financial Statements
Note 2- Summary of Significant Accounting Policies
Disaggregation of Revenues, page 17

17.    It appears from your disclosure that 100% of your revenue for the nine
months ended
       September 30, 2024 is from the sale of personal protective products.
This appears to
       be inconsistent with your disclosure on page 14 of your 10-Q for the six
months ended
       June 30, 2024 which states 100% of your review is from guard services
provided.
       Please clarify or revise.
Note 4 - Intangible Assets, page 18

18.    Please tell us why you did not recognize any amortization for your
intangible assets
       during the nine month period ended September 30, 2024.
Note 6 - Debt
Loans Payable, page 25

19.    It appears from your disclosure on page F-19 of your December 31, 2023
10-K that
       you had a $ 466,000 loan agreement NewTek Small Business Finance, LLC
that had
       an outstanding principal balance of $398,533 at December 31, 2023. It
does not
       appear that this loan agreement has been accounted for in outstanding
loans at
       September 30, 2024. Please clarify or revise.
Note 10- Stockholders' Deficit
Stock Issued for Service - Related Party, page 33

20.    We note from your disclosure that you determined the fair value of the
Series B
       Preferred Stock issued for consulting fees in accordance with ASC 470
Debt   , under
       its parity value (as-converted value). Please tell us the specific
paragraph of the
       guidance that supports your accounting treatment and why the fair value
of the
       consulting fees was not utilized to determine the fair value of the
preferred stock
       issued if it was more readily determinable. In addition, please tell us
how you
       accounted for the conversion feature of the Series B Preferred Stock and
cite the
       specific authoritative accounting literature you utilized to support
your accounting
       treatment.
Stock and Warrants Issued for Cash, page 33

21.    Please tell us how you accounted for the warrants issued with common
stock and cite
       the specific authoritative accounting literature you utilized to support
your accounting
       treatment.
 December 11, 2024
Page 5

        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 Keira Nakada at 202-551-3659 or Angela Lumley at
202-551-3398 if
you have any questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Trade &
Services