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CORRESP
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    Austin
    Legal Group, APC

    Lawyers

    3990
    Old Town Ave, Ste A-101

    San
    Diego, CA 92110

    Telephone

    (619)
    924-9600

    Facsimile
    Writer’s
    Email:

    (619)
    881-0045
    gaustin@austinlegalgroup.com

January
23, 2025

U.S.
Securities and Exchange Commission

Division
of Corporate Finance

Office
of Real Estate & Construction

100
F Street, NE

Washington,
D.C. 20549

Attn:
Dorrie Yale and Catherine De Lorenzo

    Re:

    JFB
    Construction Holdings

    Registration
    Statement on Form S-1/A Submitted January 22, 2025

    CIK
    No.: 0002024306

Dear
Ms. Yale and De Lorenzo:

Please
see below for responses to the Division’s letter dated January 13, 2025 regarding the above captioned matter. All comments have
been addressed in the Registration Statement on Form S-1, filed January 22, 2025 (“Amendment”) and/or as further herein
detailed.

Amendment
No. 2 to Registration Statement on Form S-1

Management’s
Discussion and Analysis of Financial Condition and Results of Operation

Current,
contracted and prospective projects, page 33

    1.
    We
    acknowledge your revised disclosures in response to prior comment 1. To the extent correct, please revise to clarify that these preliminary
    amounts do not include certain costs, such as interest expense, and to clearly explain that these financial measures are partial
    and preliminary, or advise.

    Response:
    The
    Company acknowledges the Staff’s comments and has included statements to clarify that the projected revenue in this section
    is based on unaudited, partial and preliminary financial data that contains estimates for transactions that have not yet been completed
    and may be subject to change based on actual returns.

    U.S. Securities and Exchange Commission

January
                                            23, 2025

Page 2

Notes
to the Unaudited Financial Statements

Note
10 - Equity, page F-30

    2.
    We
    note from your response to prior comment 3 that services outlined in the agreement with Chartered Services have no specific deadlines
    or deliverables and that services are not directly related to the IPO. However, we also note your disclosure on page F-14 that Chartered
    Services is to provide strategic consulting services related to the company’s IPO for six months unless otherwise earlier terminated
    due to breach of the agreement by either party and the failure to cure such breach 30 days after written notice thereof. Please reconcile
    these discrepancies. Additionally, we note your reference to ASC 505-50 to assess the value of the services provided by Chartered
    Services. Please tell us how you considered the guidance in ASC 718 to account for your share-based compensation and revise your
    disclosure accordingly.

    Response:
    The
    Company acknowledges the Staff’s comments and has revised its disclosures to reflect the proper fair value evaluation consistent
    with ASC 718. As noted in our revised disclosure, there were a number of potential services to be provided, with IPO
    services being only one small potential service named in the agreement. The Company has amended its agreement with Chartered
    Services to clearly reflect the intention of the parties and potential IPO services has been removed from the agreement. Additionally,
    the agreements contain no deliverables or performance milestones from Chartered Services and the Company cannot require the shares
    to be returned even if the agreement is cancelled for non-performance by the Company. As a result, the full fair value of the shares
    has been expensed in the current period as there is no clear remaining requisite service period.

If
you have any questions relating to any of the foregoing, please contact Gina Austin, Esq. of Austin Legal Group, APC at (619) 924-9600.

    Sincerely,

    AUSTIN
    LEGAL GROUP, APC

    /s/
    Gina Austin, Esq.

    Gina
    Austin, Esq.