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    G. Alex Weniger-Araujo

    Partner

    345 Park Avenue
    Direct
    212.407.4063

    New York, NY  10154
    Main
    212.407.4000

    Fax
    212.407.4990

    aweniger@loeb.com

December 9, 2022

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549

  Re:
  Revelstone Capital Acquisition Corp.

Form 10-K for fiscal year
ended December 31, 2021 Filed April 5, 2022

File No. 001-41178

Attention: Mark Rakip and Kristi Marrone

On behalf of our client, Revelstone
Capital Acquisition Corp., a Delaware corporation (“Revelstone” or the “Company”), we respond to the comments
of the staff of the Division of Corporation Finance of the Commission (the “Staff”) with respect to the above-referenced report
for the fiscal year filed on Form 10-K on April 5, 2022 (the “10-K”) contained in the Staff’s letter dated December
8, 2022 (the “Comment Letter”).

For ease of reference, the
comment contained in the Comment Letter is printed below and is followed by the Company’s response.

Form 10-K for fiscal year ended
December 31, 2021 General

 1. With a view toward disclosure, please tell us whether your sponsor is, is
                                                                 controlled by, or has substantial ties with a non-U.S. person. If so, please revise your disclosure in future filings to include
                                                                 disclosure that addresses how this fact could impact your ability to complete your initial business combination. For instance,
                                                                 discuss the risk to investors that you may not be able to complete an initial business combination with a U.S. target company should
                                                                 the transaction be subject to review by a U.S. government entity, such as the Committee on Foreign Investment in the United States
                                                                 (CFIUS), or ultimately prohibited. Disclose that as a result, the pool of potential targets with which you could complete an initial
                                                                 business combination may be limited. Further, disclose that the time necessary for government review of the transaction or a
                                                                 decision to prohibit the transaction could prevent you from completing an initial business combination and require you to liquidate.
                                                                 Disclose the consequences of liquidation to investors, such as the losses of the investment opportunity in a target company, any
                                                                 price appreciation in the combined company, and the warrants, which would expire worthless.
Please include an example of your intended disclosure in your response.

    G. Alex Weniger-Araujo

    Partner

    345 Park Avenue
    Direct
    212.407.4063

    New York, NY 10154
    Main
    212.407.4000

    Fax
    212.407.4990

    aweniger@loeb.com

Response:
Our sponsor, Revelstone Capital, LLC is controlled by Daniel Neukomm and Morgan Callagy, each a USA citizen, and both serve as our co-chief
executive officers. Neither Mr. Neukomm or Mr. Callagy will remain with the combined company after the initial business combination. For
these reasons, we do not expect the post-combination company to be considered a “foreign person” under the regulations administered
by CFIUS.

    Sincerely,

    G. Alex Weniger-Araujo