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 July 11, 2025

Paulo Bonifacio
Chief Executive Officer
BRB Foods Inc.
Rua Doutor Eduardo de Souza Aranha
387 Conjunto 151
Sao Paulo, SP, Brazil 04543-121

 Re: BRB Foods Inc.
 Amendment No. 11 to Registration Statement on Form S-1
 File No. 333-276557
 Filed on July 1, 2025
Dear Paulo Bonifacio:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our June 2, 2025
letter.

Amendment No. 11 to Registration Statement on Form S-1
Summary, page 4

1. We note your response to our prior comment 6. Please update your Summary
section
 to reflect the updates made to the discussion of your strategic
planning.
Risk Factors, page 11

2. We note your response to our prior comment 3 and partially reissue.
Where you
 discuss market share, customers and vendors, revise to specifically
address any
 challenges associated with the suspension of sales and the obstacles you
could face
 when you attempt to reenter the market. We note risk factors regarding
customer and
 vendor reliance on pages 13 and 14, respectively.
 July 11, 2025
Page 2

Use of Proceeds, page 41

3. We note your disclosure that you intend to use up to 10% of the net
proceeds for
 "potential strategic investments in unaffiliated entities or joint
ventures." Please
 provide the information required by Instruction 6 to Item 504 of
Regulation S-K.
Unaudited Consolidated Financial Statements for the Three Months Ended March
31, 2025,
page F-2

4. Please revise to clearly label the interim financial statements as
unaudited. Include
 that label on each of the primary financial statements and the first
page of the notes to
 financial statements. In addition, correct the footnote at the bottom of
pages F-2
 through F-7 to state that the notes are an integral part of these
unaudited
 consolidated financial statements.
5. Please revise to label each column of the corrected financial
information as "restated"
 as appropriate throughout the filing, including in the interim financial
statements. For
 example, on the interim balance sheet on page F-2, the column for the
year ended
 December 31, 2024 should be marked as "restated." Additionally, please
include all
 disclosures required by ASC 250-10-50-7.
6. We note your response to our prior comment 14 and revised disclosures
for the related
 restatement. However we note from your disclosure in the notes to the
financial
 statements that the deferred offering costs related to legal and
consulting services of
 $1,025,195 are currently presented as amortizable intangible assets as
of March 31,
 2025 and December 31, 2024 and 2023. Please revise to appropriately
describe and
 classify these deferred offering costs. The comment applies to both sets
of the
 financial statements.
Statement of Changes to Shareholders' Equity, page F-5

7. We note that your Statement of Changes to Shareholders Equity
includes a
 rollforward of the year ended December 31, 2024 and the period ended
March 31,
 2025. In accordance with Rule 8-03(a)(5) and Rule 3-04 of Regulation
S-X, please
 revise to include a rollforward of the comparative year-to-date period
which would
 reflect the activity during the time between December 31, 2023 and March
31, 2024.
Audited Financial Statements for the Year Ended December 31, 2024
Notes to the Audited Financial Statements
Note 4. Main Accounting Practices
Consolidated Financial Statements Restated, page F-47

8. We note your disclosure that you have updated the disclosures and
footnotes related to
 intangible assets regards to financial statements of fiscal year ended
as of
 December 31, 2024 and 2023, and recorded a GAAP adjustment of USD
1,166,238
 and USD 1,140,815 respectively. Please revise to include all disclosures
required by
 ASC 250-10-50-7. This guidance includes disclosure of the amount of the
adjustment
 for each financial statement line item that was affected in the
restatement as well as
 loss per share amounts, and should be shown for both 2024 and 2023.
Please revise
 accordingly.
 July 11, 2025
Page 3

Part II
Item 16. Exhibits and Financial Statement Schedules., page II-3

9. We note that you have redacted information from Exhibits 10.1, 10.2,
10.3 and 10.4,
 but that the identification key you provide on page II-4 does not
indicate that these
 exhibits contain redactions. Please revise.
 Please contact Stephany Yang at 202-551-3167 or Claire Erlanger at
202-551-3301 if
you have questions regarding comments on the financial statements and related
matters. Please contact Sarah Sidwell at 202-551-4733 or Erin Purnell at
202-551-3454 with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
cc: Mitchell Lampert
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