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CORRESP
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 300 North LaSalle Dr.
Chicago, IL 60654-3406

 Direct Tel: 312 728 9158

 Mobile: 312 927 0860

 November 20, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Real Estate & Construction

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Peter McPhun, Jennifer Monick, Ruairi James Regan, and Pamela Long

 Re: Cardinal Infrastructure Group Inc. (f/k/a Civil Infrastructure
Group Inc.)
Registration Statement on Form S-1 Filed October 14, 2025
File No. 333-290850

 Ladies and Gentlemen:

 On behalf of Cardinal
Infrastructure Group Inc. (the " Company "), we submit this letter in response to the comment letter received
by the Company on November 18, 2025 from the staff (the " Staff ") of the Securities and Exchange Commission (the
" SEC ") regarding the above referenced Registration Statement on Form S-1 previously filed by the Company on
October 14, 2025 (the " Registration Statement ").

 For ease of review, we have set forth below each
of the numbered comments of your letter in bold type followed by the Company's responses thereto. Unless otherwise indicated, capitalized
terms used herein have the meanings assigned to them in Amendment No. 1 to the Registration Statement (" Amendment No. 1 ")
which is being filed herewith, and all references to page numbers in such responses are to page numbers in Amendment No. 1.

 Management Discussion and Analysis of Financial Condition
and Results of Operations Capital Expenditures, page 86

 1. We note your disclosure that defines maintenance capital expenditures as representing recurring investments made to preserve the
operating capacity, safety, and regulatory compliance of your existing fleet, equipment, and infrastructure assets. In addition, you state
that such maintenance capital expenditures do not expand capacity or materially enhance performance, but are necessary to sustain current
operations. Also, we note your disclosure on page F-13 that expenditures for repairs and maintenance which do not improve or extend the
life of an asset are charged to expense as incurred. Please clarify for us if maintenance capital expenditures are reported in property
and equipment on your balance sheets. If yes, please explain the basis for this accounting treatment and provide the authoritative accounting
literature management relied upon.

 Response :
The Company acknowledges the Staff's comment and has revised the disclosure on page 85 of Amendment No. 1. The Company
further clarifies that maintenance capital expenditures are reported in property and equipment on the Company's balance sheets
when maintenance capital expenditures meet the capitalization criteria under ASC 360. Such expenditures often involve purchases of
new assets to replace older assets that have reached the end of their useful lives, thereby preserving operating capacity. In
contrast, routine repairs and maintenance that do not improve or extend the life of an asset are expensed as incurred, as disclosed
on page F-15 of Amendment No. 1. The Company advises the Staff that the Company's definition of maintenance capital
expenditures is intended to distinguish these recurring capitalized investments from growth capital expenditures, which expand
capacity or materially enhance performance.

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 We would like to express our appreciation in advance
for your prompt attention to Amendment No. 1 and are available to discuss any of the Company's responses with you at your earliest
convenience. If you have any questions regarding the foregoing responses or the Amendment No. 1, please do not hesitate to contact me
by direct telephone at 312-728-9158.

 Very truly yours,

 /s/ Edward S. Best

 Edward S. Best

 Enclosure

 cc: Jeremy Spivey, Chief Executive Officer Cardinal Infrastructure
Group Inc.
Mike Rowe, Chief Financial Officer, Cardinal Infrastructure Group Inc.
Tiffany Gidley, General Counsel, Cardinal Infrastructure
Group Inc.