February 14, 2025

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

       Re: James Maritime Holdings Inc.
           Amendment No. 1 to Form 10-K for Fiscal Year Ended December 31, 2023
           Form 10-Q for Quarterly Period Ended September 30, 2024
           Response Dated January 31, 2025
           File No. 000-21322
Dear Kip Eardley:

       We have reviewed your January 31, 2025 response to our comment letter
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.
Unless we note otherwise, any references to prior comments are to comments in
our
December 11, 2024 letter.

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.     We have reviewed your response to prior comment 1 noting it does not
appear to
       address our comment. Please revise your discussion to quantify the
increase in
       revenue and cost of goods sold recognized through USS, quantify the
decrease in
       overhead expenses that were included in cost of goods sold, and provide
an example
       of your revised discussion for the quarterly period ended September 30,
2024.
 February 14, 2025
Page 2

       In addition, please confirm that you will revise your discussions of
results of
       operations to provide a similar level of detail in future filings,
including amendments
       to Forms S-1, 10-K, and 10-Q.
General and Administrative, page 16

2.     We note your response to prior comment 2. Please confirm that you will
quantify each
       material factor that is attributable to the fluctuations in your general
and
       administrative expenses in your future discussions of results of
operations, including
       amendments to Forms S-1, 10-K, and 10-Q.
9. Loans, current and non-current, page F-18

3.     We have reviewed your responses to prior comments 11 and 19 noting the
responses
       appear to be inconsistent with the actual disclosure here and on page 26
of the
       September 30, 2024 Form 10-Q. Per the disclosure here, the $398,533
outstanding
       balance at December 31, 2023 relates to a $466,000 loan received from
NewTek
       entered into in December 2020. The $398,533 outstanding loan balance
disclosed on
       page 26 in the September 30, 2024 Form 10-Q is disclosed as a factoring
agreement
       with Bayview that was entered into in April 2023. It appears these are
two different
       loans with different origination dates, interest rates, and payment
terms. It does not
       appear to be the same loan that was incorrectly labeled with the wrong
name. Please
       clarify or revise.
Form 10-Q for the Nine Months Ended September 30, 2024
Condensed Consolidated Statement of Operations (Unaudited), page 6

4.     We have reviewed your response to prior comment 16. Please provide us
with a
       detailed discussion of the circumstances that resulted in the $1,091,374
payroll tax
       overpayment without your detection, including the duration over which
the
       overpayment was accumulated, the amount of underlying payroll expense,
and the
       amount of the actual payroll taxes. In addition, clarify your statement
that your payroll
       provider inadvertently debited your account for the taxes as it is
unclear whether the
       payroll taxes were not correctly calculated or your payroll provider was
making
       payments above the calculated amounts. Lastly, provide us with your
analysis of
       whether this overpayment was an error under ASC 250.
Notes to Unaudited Condensed Consolidated Financial Statements
Note 4 - Intangible Assets, page 22

5.     We have reviewed your response to prior comment 18 noting you determined
the
       error of not recording amortization expense related to intangible assets
for the quarter
       ended September 30, 2024 was quantitatively material, but not
qualitatively material,
       therefore revising your financial statements for this error would not be
meaningful.
       Please provide us with your analysis regarding how you determined the
materiality in
       the current period and all previous periods as it appears that
amortization expense
       related to intangible assets was also not recorded for the quarters
ended March 31,
       2024 and June 30, 2024. Please refer to SAB Topics 1.M. and 1.N. when
preparing
       your response.
 February 14, 2025
Page 3

       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