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CORRESP

 August 28, 2013

 Securities and Exchange Commission

 Division of Corporation Finance

100 F Street, N.E.

 Washington, D.C. 20549

Attention:

Leland Benton

Craig E. Slivka

Re:
LGI Homes, Inc.

 Draft
Registration Statement on Form S-1

 Submitted July 10, 2013

CIK No. 0001580670

Ladies and Gentlemen:

 Set
forth below are the responses of LGI Homes, Inc. (the “Company”) to the comments contained in the letter from the staff (the “Staff”) of the Securities and Exchange Commission, dated August 6, 2013, with respect to the
above-captioned submission.

 Concurrently with the submission of this letter, the Company has filed publicly its Registration
Statement on Form S-1 (the “Registration Statement”) via EDGAR. For your convenience, five marked copies of the Registration Statement will be hand delivered to you to facilitate your review. Furthermore, the Company is sending via
overnight delivery service certain supplemental information responsive to the Staff’s requests in comments 5, 7 and 8 in separate correspondence.

 For your convenience, the Company has repeated in italics the comments and requests for additional information as set forth in the Staff’s comment letter. The Company’s response to each comment
or request is set forth immediately below the text of the applicable comment or request. Capitalized terms used but not defined in this letter shall have the meanings assigned to such terms in the Registration Statement.

General

1.
Please be advised that we will process this filing and any amendments without a price range. Since the price range triggers a number of disclosure matters, we will
need sufficient time to process the amendment when it is included. Please understand that its effect on disclosure throughout the document may cause us to raise issues on areas not previously commented upon.

Response:

 The Company acknowledges the
Staff’s comment.

2.
 As indicated in the comment above, we note that you have omitted certain pricing-related information as well as other information from this filing.
If you intend to rely on Rule 430A, please note that Rule 430A does not allow for the omission prior to effectiveness of amounts that may be computed based on the maximum number of shares offered and

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the mid-point of the offering price range, or the number of shares to be offered on the cover. In addition, please confirm that you will not circulate copies of the registration statement or the
preliminary prospectus until you include an estimated price range, maximum number of shares, dollar amounts dependent upon the offering price that are based on the mid-point of the offering price range, and all other information except information
you may exclude in reliance upon Rule 430A.

 Response:

 The Company acknowledges the Staff’s comment and confirms that it will not circulate copies of the Registration Statement or the preliminary prospectus until the Company has included an estimated
price range, maximum number of shares, dollar amounts dependent upon the offering price that are based on the mid-point of the offering price range, and all other information except information the Company may exclude in reliance upon Rule 430A.

3.
We encourage you to file all exhibits with your next amendment. Please understand that we will need adequate time to review these materials before effectiveness. In
addition, please file a copy of your LLC Operating Agreement with your next amendment.

 Response:

The Company acknowledges the Staff’s comment. The Certificate of Formation of LGI Homes Group, LLC and the First Amended and Restated Company
Agreement of LGI Homes Group, LLC have been filed as Exhibits 3.3 and 3.4 to the Registration Statement.

4.
Prior to the effectiveness of the registration statement, please arrange to have FINRA call us or provide us with a letter indicating that FINRA has cleared the
underwriting arrangements for the offering.

 Response:

 The Company acknowledges the Staff’s comment and confirms that, prior to the effectiveness of the Registration Statement, the Company will arrange to have FINRA call the Staff or provide the Staff
with a letter indicating that FINRA has cleared the underwriting arrangements for the offering.

5.
 You appear to qualify as an “emerging growth company,” as defined in the Jumpstart Our Business Startups Act. Please supplementally
provide us with copies of all written communications, as defined in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf, present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they retain copies of the communications. Similarly, please supplementally provide us with any research reports about you that are published or distributed in reliance

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upon Section 2(a)(3) of the Securities Act of 1933 added by Section 105(a) of the Jumpstart Our Business Startups Act by any broker or dealer that is participating or will participate
in your offering.

 Response:

 In response to the Staff’s comment, the Company will supplementally provide to the Staff in separate correspondence, a copy of the presentation attached thereto as Exhibit A (the
“Presentation”) that was made by the Company to potential investors in reliance on Section 5(d) of the Securities Act of 1933, as amended (the “Securities Act”).

 The Company asserts that the Presentation used by the Company constituted written “test the waters” communications, which assertion is based on (i) its status as an emerging growth company
as defined in the Jumpstart Our Business Startups Act (the “JOBS Act”) and (ii) its belief, based on confirmation from the underwriters, that each of the potential investors that received the Presentation were “qualified
institutional buyers” (as defined in Rule 144A of the Securities Act) or institutions that are “accredited investors” (as defined in Regulation D of the Securities Act). Potential investors did not retain any copies of the
Presentation.

 Other than the Presentation, no other written communications have been presented by the Company or, to its knowledge, anyone
acting on its behalf to potential investors in reliance on Section 5(d) of the Securities Act.

 No research reports about the Company
have been, or to the Company’s knowledge, will be, published or distributed in reliance upon Section 2(a)(3) of the Securities Act added by Section 105(a) of the JOBS Act by any broker or dealer that is participating or will
participate in the offering.

6.
Please revise to include a reasonably detailed table of contents on either the inside front or outside back cover page of the prospectus. Please see Item 502(a)
of Regulation S-K.

 Response:

 The Company acknowledges the Staff’s comment and has revised the table of contents in the Registration Statement accordingly. Please see pages i-ii of the Registration Statement.

7.
 Please supplementally provide supporting documentation for all of the statistical and similar disclosure you make in your prospectus, particularly
with regard to the business performance of your peers. Please ensure that the manner in which your peer group was selected and the group of comparators you refer to is clear from your supplemental response. For example, we refer you to the
statements on page one and throughout your prospectus, among others, to the effect that: you are one of the nation’s fastest growing homebuilders; that you have industry-leading build times; that you had the highest revenue, closings growth,
return of

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assets, asset turnover, and closings per active community of public homebuilders. Please provide necessary context (for example, the number of homes in each of your active communities versus your
comparator group.) Please mark the supporting documents to show precisely the location of each piece of information on which you are relying for these and similar statements in your prospectus.

Response:

 In response to the
Staff’s comment, the Company will supplementally provide to the Staff in separate correspondence supporting documentation attached thereto as Exhibit B.

8.
Please provide similar substantiation for the more qualitative statements throughout your prospectus, such as, for example: that you offer superior value; that you
have a strong land position; that your markets are attractive; that unlike many of your competitors, you acquire finished lots and raw land in affordable locations with proximity to major thoroughfares, retail districts and centers of business; that
your print and digital advertising is innovative; and so forth.

 Response:

The Company believes that its focus on lots and land further away from city centers allows the Company to offer potential homebuyers a superior value on
homes. The Company generally acquires lots and land further away from the center of metropolitan areas and purchases lots and land at prices ranging from $9,000 to $25,000 per acre. Based on its discussions with land brokers and others in the real
estate market, the Company believes its competitors typically acquire similar acreage closer to city centers at higher prices. In addition, the Company targets affordable land acquisitions with proximity to major thoroughfares, retail districts and
centers of business. The Company will supplementally provide to the Staff in separate correspondence supporting documentation attached thereto as Exhibit C for the above statements. The Company requests confidential treatment for these
materials pursuant to 17 C.F.R. § 200.83.

 As of June 30, 2013, the Company owned or controlled 9,962 lots. The Company believes it
has a strong land position because it has more than seven years of land supply, based on the lots that it owned or controlled as of June 30, 2013 and its home closings for the twelve months ended June 30, 2013.

The Company believes its markets are attractive because many of the Company’s existing markets, including Austin, Houston, Dallas/Fort Worth,
Phoenix and San Antonio, are ranked among the top 10 markets for fastest population growth in the United States from 2000 to 2010, according to the U.S. Census Bureau. In addition, according to John Burns Real Estate Consulting, LLC
(“JBREC”), all of the Company’s existing markets, except for San Antonio, experienced job growth above the national average in the twelve months ended June 30, 2013, while San Antonio matched the national average. According to
JBREC, all of the Company’s markets experienced increased new homes sales in the twelve months ended June 30, 2013.

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 The Company believes that it makes extensive use of advertising because of its direct mailing program.
Each week, the Company sends an average of 12,000 direct mailings to renters within a 25-mile radius of each of its active communities. The Company is not aware of any of its competitors that employ a direct mailing program on this scale. The
Company also believes this direct mailing program aimed at renters of apartments and single-family homes allows the Company to more specifically target entry level homebuyers.

 The Company employs an even-flow construction methodology, which provides a consistent flow of work for its subcontractors. The Company believes this methodology results in favorable relationships with
subcontractors who prefer the stability of this method. The Company will supplementally provide to the Staff in separate correspondence supporting documentation attached thereto as Exhibit C for these statements. The Company requests
confidential treatment for these materials pursuant to 17 C.F.R. § 200.83.

 The Company has modified the disclosure in the Registration
Statement relating to certain of these qualitative statements. Please see pages 2, 3, 138, 140 and 146 of the Registration Statement.

Summary, page one

9.
Please ensure that the information you include in your summary is balanced. To the extent that you continue to cite competitive strengths in your summary, please
review each one and revise as necessary to provide balancing information rather than a simple list of risk factors at the end of this section.

 Response:

 The Company acknowledges the Staff’s comment and has revised the Summary
section of the Registration Statement accordingly. Please see pages 4 and 142-143 of the Registration Statement.

10.
Please identify those aspects of the offering and your company that are most significant, and highlight these points in plain, clear language. The summary should
not, and is not required to repeat the detailed information in the prospectus. The detailed description of your business, competitive strengths, and strategy is unnecessary since you repeat them verbatim in the business section of the prospectus.

 Response:

The Company acknowledges the Staff’s comment. While the Summary section of the Registration Statement was a condensed description of the
Company’s business, competitive strengths and strategy in the Business section, the Company has further condensed the information in the Summary section to focus on the aspects of the offering and the Company that are most significant. Please
see pages 1-7 of the Registration Statement.

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 Proven ability to expand into new geographic markets, page five

11.
Please disclose the basis of the in-depth local market knowledge that you refer to in the final sentence under this paragraph as it relates to the Tampa, Atlanta,
and Orlando markets, which you have recently entered, and the similar reference to “[y]our familiarity with each of [y]our existing markets” on the following page.

 Response:

 The Company acknowledges the Staff’s comment and has disclosed that the new
employees that the Company has hired in the Tampa, Atlanta and Orlando markets have in-depth local market knowledge of each of those markets. Please see pages 4-5 and 143-144 of the Registration Statement.

The Transactions, page nine

12.
Supplementally, please tell us the exemption under which the securities in the formation transactions will be issued.

Response:

 The shares of the
Company’s common stock to be issued in the Formation Transactions will be issued pursuant to Section 4(a)(2) of the Securities Act and Rule 506 of Regulation D thereunder.

 Risks Related to Our Business, page 18

 Continued or additional tightening of
mortgage lending standards and mortgage financing requirements and rising interest rates could adversely affect the availability of mortgage loans for potential purchasers of our homes and thereby reduce our sales, page 18

13.
You state in the second paragraph under this heading that if the USDA rural development program is discontinued or funding is decreased, then your business could be
affected. Please disclose where this program is available, and what percentage of your inventory may be affected.

Response:

 The Company acknowledges the
Staff’s comment and has disclosed that the USDA rural development program is available in all of the Company’s markets and affects 65% of the Company’s active communities as of June 30, 2013. Please see page 17 of the
Registration Statement.

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 Labor and raw material shortages and price fluctuations could delay or increase the cost of home
construction, which could materially and adversely affect us, page 20

14.
In the third sentence under this heading you state that certain of your markets have begun to exhibit a scarcity of skilled labor. Please clarify which markets you
are referring to, and how your expansion plans may be affected.

 Response:

The Company acknowledges the Staff’s comment and has clarified tha