SecProbe.io

CORRESP
 1
 filename1.htm

 BUDA
JUICE, INC.

 4030
Black Gold Drive

 Dallas,
TX 75247

 January
7, 2026

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Trade and Services

 100
F Street, N.E.

 Washington,
D.C. 20549

 Re:
 Buda
 Juice, Inc.

 Registration
 Statement on Form S-1

 Filed
 August 27, 2025, as amended

 File
 No. 333-289874

 REQUEST FOR ACCELERATION OF EFFECTIVENESS

 Ladies
and Gentlemen,

 Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Buda, Juice, Inc. (the "Company"), hereby requests acceleration
of effectiveness of the above referenced Registration Statement on Form S-1 (File Number 333-289874), as amended so that it will become
effective at 4:30 p.m., Eastern Time, on Wednesday, January 7, 2026, or as soon thereafter as practicable.

 Please
contact our counsel, Soyoung Lee, Esq. of Lucosky Brookman LLP at (917) 445-1199 with any questions you may have regarding this request.
In addition, the Company requests that you kindly notify Ms. Lee by telephone when this request for acceleration has been granted.

 Very
 truly yours,

 /s/
 Horatio Lonsdale-Hands

 Horatio
 Lonsdale-Hands

 Chief
 Executive Officer

CORRESP
 1
 filename1.htm

 BUDA
JUICE, INC.

 4030
Black Gold Drive

 Dallas,
TX 75247

 January
6, 2026

 VIA
EDGAR

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Trade and Services

 100
F Street, N.E.

 Washington,
D.C. 20549

 Re:
 Buda
 Juice, Inc.

 Registration
 Statement on Form S-1

 Filed
 August 27, 2025, as amended

 File
 No. 333-289874

 REQUEST FOR ACCELERATION OF EFFECTIVENESS

 Ladies
and Gentlemen,

 Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Buda, Juice, Inc. (the "Company"), hereby requests acceleration
of effectiveness of the above referenced Registration Statement on Form S-1 (File Number 333-289874), as amended so that it will become
effective at 4:30 p.m., Eastern Time, on Wednesday, January 7, 2026.

 Please
contact our counsel, Soyoung Lee, Esq. of Lucosky Brookman LLP at (917) 445-1199 with any questions you may have regarding this
request. In addition, the Company requests that you kindly notify Ms. Lee by telephone when this request for acceleration has been granted

 Very
 truly yours,

 /s/
 Horatio Lonsdale-Hands

 Horatio
 Lonsdale-Hands

 Chief
 Executive Officer

CORRESP
 1
 filename1.htm

 Public
Ventures, LLC

 14135
Midway Road, Suite G-150

 Addison,
Texas 75001

 (T)
945-262-9010

 January
6, 2026

 Via
EDGAR Transmission

 Securities
and Exchange Commission

 Division
of Corporation Finance

 100
F. Street, N.E.

 Washington,
D.C. 20549

 Re:
 Buda
 Juice, LLC/Buda Juice, Inc.

 Registration
 Statement on Form S-1

 File
 No. 333-289874

 Ladies
and Gentlemen:

 In
connection with the Registration Statement on Form S-1 of Buda Juice, Inc. (the "Company"), the undersigned hereby
joins the request of the Company that the effectiveness of said Registration Statement be accelerated to 4:30 p.m. Eastern time on Wednesday,
January 7, 2026, or as soon thereafter as practicable.

 Very
 truly yours,

 PUBLIC
 VENTURES, LLC

 By:
 /S/
 Gary Schuman

 Name:
 Gary
 Schuman

 Title:
 CFO
 & CCO

CORRESP
 1
 filename1.htm

 Public
Ventures, LLC

 14135
Midway Road, Suite G-150

 Addison,
Texas 75001

 (T)
945-262-9010

 January
6, 2026

 Via
EDGAR Transmission

 U.S.
Securities and Exchange Commission

 Division
of Corporation Finance

 100
F Street, N.E.

 Washington,
D.C. 20549

 Re:
 Buda
 Juice, LLC / Buda Juice, Inc.

 Registration
 Statement on Form S-1

 File
 No. 333-289874

 Ladies
and Gentlemen:

 In
connection with the above-captioned Registration Statement, we, the selling agent as underwriter, wish to advise you that in the aggregate
3,066 copies of the Preliminary Prospectuses dated December 17, 2025 and December 12, 2025, were distributed as follows:

 ●
 113
 copies to institutions; and

 ●
 2,953
 copies to individuals.

 The
undersigned has and will, and each dealer has advised the undersigned that it has and will, comply with the requirements of Rule 15c2-8
under the Securities Exchange Act of 1934, as amended.

 Very
 truly yours,

 PUBLIC
 VENTURES, LLC

 By:
 /S/
 Gary Schuman

 Name:
 Gary
 Schuman

 Title:
 CFO
 & CCO

CORRESP
 1
 filename1.htm

 Buda
Juice, LLC

 4030
Black Gold Drive

 Dallas,
Texas 75247

 December
17, 2025

 United
States Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Manufacturing

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attention:
Jenny O'Shanick, Anne Parker, Jeff Gordon, and Kevin Woody

 Re:
 Buda
 Juice, LLC
 Amendment
 No. 5 to Registration Statement on Form S-1 filed December 12, 2025
 File
 No. 333-289874

 Ladies
and Gentlemen:

 By
letter dated December 16, 2025, the staff (the " Staff ," " you " or " your ") of
the U.S. Securities and Exchange Commission (the " Commission ") provided Buda Juice, LLC (the " Company ,"
" we ," " us " or " our ") with its comments to the Company's Amendment No.
5 to Registration Statement on Form S-1, submitted to the Commission on December 12, 2025. We are in receipt of your letter and we respectfully
set forth below our response to your comments. For your convenience, the comment is listed below, followed by the Company's response.

 Amendment
No. 5 to Registration Statement on Form S-1

 Risk
Factors

 Risks
Relating to This Offering

 Our
Certificate of Incorporation contains an exclusive forum provision for certain claims...,

 page
31

 1. We
 note your revisions in response to prior comment 1 and reissue in part. Please address the
 part of that comment that requests disclosure of the risks related to increased costs to
 bring a claim. We also note disclosure here that the exclusive forum provision does not apply
 to actions arising under the Exchange Act or Securities Act and on page 69 that your Certificate
 of Incorporation "provides that unless we consent in writing to the selection of an
 alternative forum, the federal district courts of the United States of America shall be the
 exclusive forum for the resolution of any complaint asserting a cause of action arising under
 the Securities Act." However, these provisions do not appear in your Certificate of
 Incorporation. Please reconcile your disclosures or as appropriate revise your governing
 documents to clearly state that the exclusive forum provision does not apply to actions arising
 under the Securities Act or Exchange Act.

 Response:
 We have revised the risk factor titled "Our Certificate of Incorporation contains an exclusive forum provision for certain
claims, which could limit our stockholders' ability to obtain a favorable judicial forum for disputes with us or our directors,
officers or employees" on page 31 to disclose the risks related to increased costs to bring a claim.

 December 17, 2025

 Page 2

 We
have revised our Certificate of Incorporation and bylaws and refiled them as exhibits 3.2 and 3.3, respectively, to
state that that unless consented in writing to the selection of an alternative forum, the federal district courts of the United
States of America shall be the exclusive forum for the resolution of any complaint asserting a cause of action arising under the
Securities Act and Exchange Act.

 Principal
Stockholders, page 65

 2. We
 note your revisions in response to prior comment 5 and reissue in part. Please tell us how
 you calculated the total in the "All directors and executive officers as a group"
 row under the "Beneficial Ownership After the Offering Common Stock" column.
 In this regard, it appears that Horatio Lonsdale-Hands's beneficial ownership should
 reflect the Stock Redemption of 500,000 shares per footnote (5). However, the difference
 between the "Beneficial Ownership Before the Offering Common Stock" and "Beneficial
 Ownership After the Offering Common Stock" columns is 666,667, instead of 500,000.

 Response:
 We have revised the "Principal Stockholders" table on page 65 to correct the "Beneficial Ownership After the Offering
– Common Stock" column for Horatio Lonsdale-Hands so that it reflects the Stock Redemption of 500,000 shares described in
footnote (5). As revised, the difference between Mr. Lonsdale-Hands's beneficial ownership before and after the offering is 500,000
shares, and the "All directors and executive officers as a group" row has been updated accordingly.

 3. We
 note that Marie Quintana will beneficially own 33,333 shares of the Company while none of
 the other directors' beneficial ownership will increase after the offering. We also
 note the disclosure on page 63 that the Company will be compensating its non-employee directors
 with equity awards upon completion of the Company's listing on NYSE. With a view toward
 disclosure, please explain each directors' beneficial ownership after the offering
 to reconcile with the director compensation disclosure on page 63. As applicable, please
 also revise to elaborate on any compensatory plan, contract or arrangement with Ms. Quintana
 here and in the Executive and Director Compensation section, and file the compensatory plan,
 contract or arrangement pursuant to Item 601(b)(10) of Regulation S-K and update the exhibit
 index.

 Response:
 We have revised the "Principal Stockholders" table on page 65 and the related footnotes to clarify that the amounts shown
in the "Beneficial Ownership After the Offering – Common Stock" column for each non-employee director include the equity
awards that the Company expects to grant to such directors upon completion of the Company's listing on NYSE American, as described
under "Director Compensation" on page 63.

 With
respect to Ms. Quintana, we have revised the disclosure to clarify that her beneficial ownership after the offering includes the equity award she will receive in connection
with her service as a director. Ms. Quintana does not have a separate compensatory agreement with the Company.

 December
 17, 2025

 Page 3

 Part
II Information Note Required in Prospectus

 Item
16. Exhibits and Financial Statement Schedules

 Exhibit
5.1 Opinion of Lucosky Brookman LLP, page II-2

 4. We
 note that you revised your opinion to cover 266,667 Representatives' Warrants and Representatives'
 Warrant Shares from the prior 306,667. Please revise Exhibit 5.1 to cover the over-allotment
 option for the Representatives' Warrants and Representatives' Warrant Shares.

 Response:
 We have revised Exhibit 5.1 to cover the over-allotment option for the Representatives' Warrants and Representatives'
Warrant Shares.

 General

 5. Please
 revise disclosures throughout the filing to update and/or reconcile apparent inconsistencies,
 including the following:

 ● We
 note your revisions to prior comment 10 and reissue in part. Reconcile references to "articles
 of incorporation and bylaws" and "certificate of incorporation and bylaws"
 to clarify if these titles refer to the same documents. Refer to pages 29, 66 and II-2.

 ● Refer
 to your footnote † on page II-2 regarding certain redactions. We note that none of
 the exhibits in the exhibit index is marked with footnote † and those redactions do
 not appear in the filed exhibits. Please advise or revise.

 Response:
 We have revised all references to "articles of incorporation and bylaws" to "certificate of incorporation and bylaws"
throughout the document and removed footnote † on page II-2 regarding certain redactions.

 Thank
you for the opportunity to respond to your comment. If you have additional questions or comments, please contact the undersigned at horatio@budajuice.com
or (214) 724-9999.

 Very
truly yours,

 /s/
 Horatio Lonsdale-Hands

 Horatio
 Lonsdale-Hands

 Chief
 Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 December 16, 2025

Horatio Lonsdale-Hands
Chief Executive Officer
Buda Juice, LLC
4030 Black Gold Drive,
Dallas, Texas 75247

 Re: Buda Juice, LLC
 Amendment No. 5 to Registration Statement on Form S-1
 Filed December 12, 2025
 File No. 333-289874
Dear Horatio Lonsdale-Hands:

 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 December 9,
2025 letter.

Amendment No. 5 to Registration Statement on Form S-1
Risk Factors
Risks Relating to This Offering
Our Certificate of Incorporation contains an exclusive forum provision for
certain claims...,
page 31

1. We note your revisions in response to prior comment 1 and reissue in
part. Please
 address the part of that comment that requests disclosure of the risks
related to
 increased costs to bring a claim. We also note disclosure here that the
exclusive forum
 provision does not apply to actions arising under the Exchange Act or
Securities Act
 and on page 69 that your Certificate of Incorporation provides that
unless we consent
 in writing to the selection of an alternative forum, the federal
district courts of the
 United States of America shall be the exclusive forum for the resolution
of any
 December 16, 2025
Page 2

 complaint asserting a cause of action arising under the Securities Act.
 However,
 these provisions do not appear in your Certificate of Incorporation.
Please reconcile
 your disclosures or as appropriate revise your governing documents to
clearly state
 that the exclusive forum provision does not apply to actions arising
under the
 Securities Act or Exchange Act.
Principal Stockholders, page 65

2. We note your revisions in response to prior comment 5 and reissue in
part. Please tell
 us how you calculated the total in the All directors and executive
officers as a group
 row under the Beneficial Ownership After the Offering Common Stock
column. In
 this regard, it appears that Horatio Lonsdale-Hands s beneficial
ownership should
 reflect the Stock Redemption of 500,000 shares per footnote (5).
However, the
 difference between the Beneficial Ownership Before the Offering
Common Stock
 and Beneficial Ownership After the Offering Common Stock columns
is 666,667,
 instead of 500,000.
3. We note that Marie Quintana will beneficially own 33,333 shares of the
Company
 while none of the other directors' beneficial ownership will increase
after the offering.
 We also note the disclosure on page 63 that the Company will be
compensating its
 non-employee directors with equity awards upon completion of the Company
 s listing
 on NYSE. With a view toward disclosure, please explain each directors'
beneficial
 ownership after the offering to reconcile with the director compensation
disclosure on
 page 63. As applicable, please also revise to elaborate on any
compensatory plan,
 contract or arrangement with Ms. Quintana here and in the Executive and
Director
 Compensation section, and file the compensatory plan, contract or
arrangement
 pursuant to Item 601(b)(10) of Regulation S-K and update the exhibit
index.
Part II Information Not Required in Prospectus
Item 16. Exhibits and Financial Statement Schedules.
Exhibit 5.1 Opinion of Lucosky Brookman LLP, page II-2

4. We note that you revised your opinion to cover 266,667 Representatives
 Warrants
 and Representatives Warrant Shares from the prior 306,667. Please
 revise Exhibit 5.1 to cover the over-allotment option for the
Representatives
 Warrants and Representatives Warrant Shares.
General

5. Please revise disclosures throughout the filing to update and/or
reconcile apparent
 inconsistencies, including the following:
 We note your revisions to prior comment 10 and reissue in part.
Reconcile
 references to articles of incorporation and bylaws and
certificate of
 incorporation and bylaws to clarify if these titles refer to the
same documents.
 Refer to pages 29, 66 and II-2.
 Refer to your footnote on page II-2 regarding certain
redactions. We note that
 none of the exhibits in the exhibit index is marked with footnote
 and those
 redactions do not appear in the filed exhibits. Please advise or
revise.
 December 16, 2025
Page 3

 Please contact Jeff Gordon at 202-551-3866 or Kevin Woody at
202-551-3629 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jenny O'Shanick at 202-551-8005 or Anne Parker at 202-551-3611 with any
other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
cc: Soyoung Lee
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 Buda Juice, LLC

 4030 Black Gold Drive

 Dallas, Texas 75247

 December 12, 2025

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Manufacturing

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Jenny O'Shanick, Anne Parker, Jeff
Gordon, and Kevin Woody

 Re:

 Buda Juice, LLC
 Amendment No. 4 to Registration Statement on Form
 S-1 filed December 1, 2025
 File No. 333-289874

 Ladies and Gentlemen:

 By letter dated December 9, 2025, the staff (the " Staff ,"
" you " or " your ") of the U.S. Securities and Exchange Commission (the " Commission ")
provided Buda Juice, LLC (the " Company ," " we ," " us " or " our ")
with its comments to the Company's Amendment No. 4 to Registration Statement on Form S-1, submitted to the Commission on December
1, 2025. We are in receipt of your letter and we respectfully set forth below our response to your comments. For your convenience, the
comment is listed below, followed by the Company's response.

 Amendment No.4 to Registration Statement on Form
S-1

 Risk Factors

 Risks Relating to This Offering, page 28

 1.
 We note that your forum selection provision identifies a state court located within the State of Delaware (or, if no state court located within the State of Delaware has jurisdiction, the federal district court for the District of Delaware) as the exclusive forum for certain litigation, including any "derivative action." Please disclose whether this provision applies to actions arising under the Securities Act or Exchange Act. If so, please also state that there is uncertainty as to whether a court would enforce such provision. Revise to discuss the risks related to increased costs to bring a claim and that these provisions can discourage claims or limit investors' ability to bring a claim in a judicial forum that they find favorable. If the provision applies to Securities Act claims, please also state that investors cannot waive compliance with the federal securities laws and the rules and regulations thereunder. In that regard, we note that Section 22 of the Securities Act creates concurrent jurisdiction for federal and state courts over all suits brought to enforce any duty or liability created by the Securities Act or the rules and regulations thereunder. If this provision does not apply to actions arising under the Securities Act or Exchange Act, please also ensure that the exclusive forum provision in the governing documents states this clearly, or tell us how you will inform investors in future filings that the provision does not apply to any actions arising under the Securities Act or Exchange Act. Finally, discuss this forum selection provision in the Description of Capital Stock section.

 Response:
 We have updated the choice of forum on pages 31 in the Risk Factors section and 67 in the Description of Capital Stock
section.

 December
12, 2025

 Page 2

 Business

 Intellectual Property, page 52

 2.
 We note your revisions in response to prior comment 8 and reissue in part. Please disclose the durations of your trademarks.

 Response: We
have updated page 52 to disclose all of our trademarks are generally renewable for successive ten-year periods.

 Management,
page 55

 3.
 We note disclosure in the table on page 55 that Mo Hayat is a director nominee and that your board is expected to be comprised of seven directors. This appears inconsistent with disclosure on page 58 that your board is expected to be comprised of six directors. Please advise or revise. Further, please update your beneficial ownership table on page 64 to provide information for Mo Hayat. Finally, please revise to update the bracketed information on pages 58 to 60 related to your director independence and committee memberships.

 Response:
 We have updated page 58 to clarify the board is expected to be comprised of seven directors. We also have updated the beneficial
ownership table on page 64 to provide information for Mo Hayat. Lastly, we have updated the bracketed information on pages 58 to 60 regarding
independent directors and committee memberships.

 Executive and
Director Compensation

 Director Compensation,
page 62

 4.
 We note your revisions in response to prior comment 11 and reissue in part. Please provide compensation information for the last completed fiscal year for Bryan Herr, Bernard Lucien Nussbaumer and Horatio Lonsdale-Hands. Refer to Item 402(r) of Regulation S-K.

 Response:
 Bryan Herr, Bernard Lucien Nussbaumer and Horatio Lonsdale-Hands did not receive any compensation for being board members
in the last completed fiscal year, nor in any year prior to that and we have revised the disclosure on page 63.

 Principal Stockholders,
page 64

 5.
 Please tell us how you calculated the totals in the "All directors and executive officers as a group" row. In this regard, it appears that the share ownership for each beneficial owner is identical in the "Beneficial Ownership Before the Offering Common Stock" and "Beneficial Ownership After the Offering Common Stock" columns except for that of Horatio Lonsdale-Hands's beneficial ownership, which reflects the Stock Redemption of 500,000 shares per footnote (4). However, the difference in the "All directors and executive officers as a group" totals for the two columns is 500,360 shares instead of 500,000 shares. Further, we note that the "All directors and executive officers as a group" row includes the shares beneficially owned by 2469447 Ontario Ltd., your 5% stockholder. However, we note that there is no indication that this stockholder is related to your directors and executive officers. Please advise or revise.

 Response: We have
revised the principal stockholders table to clarify the calculations.

 December
12, 2025

 Page 3

 Exhibit 10.1 Stock Incentive Plan, page II-2

 6.
 We note your response to prior comment 17 and reissue in part. Please file your indemnification agreements with each of your directors and executive officers. Further, please reconcile the description of Exhibit 10.1 in the exhibit index, which appears inconsistent with the exhibit title of 2025 Equity Incentive Plan. Additionally, please advise if Exhibit 10.1 is the same as the "2025 Incentive Award Plan" referenced on page 62 and revise to clarify. Finally, please revise the Executive and Director Compensation section to disclose the material terms of Exhibit 10.1 and the 2025 Incentive Award Plan.

 Response:
We have revised the description of Exhibit 10.1 in the exhibit index, updated the language to use consistent terms for the Buda Juice,
Inc. 2025 Equity Incentive Plan, and provided disclosure of its material terms. We have filed our indemnification agreement as exhibit
10.5.

 Exhibit

 107 Filing Fee Table, page II-2

 7.
 We note that you are relying on Rules 457(o) and 457(g). Please revise the "Maximum Aggregate Offering Price" column of your fee table to reflect the maximum offering price that you disclose in your prospectus for all offered securities, including the over-allotment shares to be offered to the public and underwriter warrants or advise. In this regard, it appears that you used the low end of your price range of $7.50 instead of the high end range of $9.

 Response:
 We have revised the fee table to use the high-end range of $9 to calculate "Maximum Aggregate Offering Price"
column of your fee table.

 Exhibit 5.1 Opinion of Lucosky Brookman LLP, page
II-2

 8.
 It appears that the underwriter's warrants will be governed by New York law. Refer to Sections 6(e) of the Form of Underwriter's Warrants and 8.6 of the Initial Form of Underwriting Agreement, filed as Exhibits 4.2 and 1.1, respectively. If true, please have New York counsel opine that the warrants are a binding obligation of the registrant under the law of the jurisdiction governing the warrant agreement, and update the Experts section as appropriate. Refer to Sections II.B.1.f and II.B.3.b of Staff Legal Bulletin No. 19.

 Response: We have revised the exhibit
5.1 opinion to have New York counsel opine that the warrants are a binding obligation of the registrant under the law of the state of
New York and updated the Experts section as appropriate to include the Underwriter's Warrants.

 Part II Information
Not Required in Prospectus

 Item 16. Exhibits
and Financial Statement Schedules, page II-2

 9.
 Please revise to update your exhibit index as follows:

 ●
 Please revise to update your exhibit index as follows: Please file your articles of incorporation and bylaws or instruments corresponding thereto as currently in effect. Refer to Items 601(b)(3)(i) and 601(b)(3)(ii) of Regulation S-K.

 Response: We have filed our Amended and Restated Company Agreement of Buda Juice, LLC

 ●
 We note that you deleted Exhibit 4.1 Form of Registrant's Common Stock Share Certificate. Please revise to file this exhibit.

 Response: We have added Exhibit 4.1 Form of Registrant's Common Stock Share Certificate.

 ●
 Please refile Exhibits 10.3 and 10.4 in the proper text-searchable format. Refer to Section 5.2.3.6 of the EDGAR Filer Manual (Volume II) EDGAR Filing (Version 75, June 2025) and Item 301 of Regulation S-T.

 Response:
 We have refiled exhibits 10.3 and 10.4 in proper text-searchable format.

 December
 12, 2025

 Page 4

 General

 10.
 Please revise disclosures throughout the filing to update and/or reconcile apparent inconsistencies, including the following:

 ●
 We note your response to prior comment 19 and reissue in part. We note disclosure on page 59 still provides that Barrett Evans is expected to serve on your audit committee. However, this individual is not disclosed on page 55. Please revise to clarify.

 Response: We have removed Barrett Evans from the Registration Statement.

 ●
 Reconcile disclosure on the cover page that you are registering 266,666 shares of Common Stock underlying warrants with disclosure elsewhere that this number is 266,667.

 Response:
We have revised the cover page to 266,667, consistent with the disclosure elsewhere in Registration Statement.

 ●
 Reconcile disclosure on page 8 that you intend to apply to have your Common Stock listed on NYSE with disclosure on page 74 that your Common Stock is listed on NYSE.

 Response: We have revised the disclosure on page 74 to disclose that we intend to apply to list our shares of Common Stock on the NYSE.

 ●
 We note disclosure on page 40 regarding lease obligations of (i) $188 due within the next 12 months; (ii) $683 due beyond 12 months; (iii) $793 due through 2030; and (iv) future minimum lease payments of approximately $981. It appears that these numbers should be in thousands. In this regard, refer to the disclosure on page F-10 of future lease obligations stated in thousands. Please advise or revise.

 Response: we have revised the disclosure regarding lease obligations on page 40 to reflect that these numbers are in thousands.

 ●
 Reconcile references to "articles of incorporation and bylaws," "amended and restated certificate of incorporation and amended and restated bylaws," and "certificate of incorporation and bylaws" to clarify if these titles refer to the same documents. Refer to pages 31, 65 and II-2.

 Response: We have removed the references to "amended and restated" certificate of incorporation and bylaws.

 Thank you for the opportunity to respond
to your comment. If you have additional questions or comments, please contact the undersigned at horatio@budajuice.com or (214)
724-9999.

 Very truly yours,

 /s/ Horatio Lonsdale-Hands

 Horatio Lonsdale-Hands

 Chief Executive Officer

December 9, 2025
Horatio Lonsdale-Hands
Chief Executive Officer
Buda Juice, LLC
4030 Black Gold Drive,
Dallas, Texas 75247
Re:Buda Juice, LLC
Amendment No. 4 to Registration Statement on Form S-1
Filed December 1, 2025
File No. 333-289874
Dear Horatio Lonsdale-Hands:
            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 September 23, 2025
letter.
Amendment No. 4 to Registration Statement on Form S-1
Risk Factors
Risks Relating to This Offering, page 28
We note that your forum selection provision identifies a state court located within the
State of Delaware (or, if no state court located within the State of Delaware has
jurisdiction, the federal district court for the District of Delaware) as the exclusive
forum for certain litigation, including any “derivative action.” Please disclose whether
this provision applies to actions arising under the Securities Act or Exchange Act. If
so, please also state that there is uncertainty as to whether a court would enforce such
provision. Revise to discuss the risks related to increased costs to bring a claim and
that these provisions can discourage claims or limit investors’ ability to bring a claim 1.

December 9, 2025
Page 2
in a judicial forum that they find favorable. If the provision applies to Securities Act
claims, please also state that investors cannot waive compliance with the federal
securities laws and the rules and regulations thereunder. In that regard, we note that
Section 22 of the Securities Act creates concurrent jurisdiction for federal and state
courts over all suits brought to enforce any duty or liability created by the Securities
Act or the rules and regulations thereunder. If this provision does not apply to actions
arising under the Securities Act or Exchange Act, please also ensure that the exclusive
forum provision in the governing documents states this clearly, or tell us how you will
inform investors in future filings that the provision does not apply to any actions
arising under the Securities Act or Exchange Act. Finally, discuss this forum selection
provision in the Description of Capital Stock section.
Business
Intellectual Property, page 52
2.We note your revisions in response to prior comment 8 and reissue in part. Please
disclose the duration of your trademarks.
Management, page 55
3.We note disclosure in the table on page 55 that Mo Hayat is a director nominee and
that your board is expected to be comprised of seven directors. This appears
inconsistent with disclosure on page 58 that your board is expected to be comprised of
six directors. Please advise or revise. Further, please update your beneficial ownership
table on page 64 to provide information for Mo Hayat. Finally, please revise to update
the bracketed information on pages 58 to 60 related to your director independence and
committee memberships.
Executive and Director Compensation
Director Compensation, page 62
4.We note your revisions in response to prior comment 11 and reissue in part. Please
provide compensation information for the last completed fiscal year for Bryan Herr,
Bernard Lucien Nussbaumer and Horatio Lonsdale-Hands. Refer to Item 402(r) of
Regulation S-K.
Principal Stockholders, page 64
5.Please tell us how you calculated the totals in the “All directors and executive officers
as a group” row. In this regard, it appears that the share ownership for each beneficial
owner is identical in the “Beneficial Ownership Before the Offering Common Stock”
and “Beneficial Ownership After the Offering Common Stock” columns except for
that of Horatio Lonsdale-Hands’s beneficial ownership, which reflects the Stock
Redemption of 500,000 shares per footnote (4). However, the difference in the “All
directors and executive officers as a group” totals for the two columns is 500,360
shares instead of 500,000 shares. Further, we note that the “All directors and
executive officers as a group” row includes the shares beneficially owned by 2469447
Ontario Ltd., your 5% stockholder. However, we note that there is no indication that
this stockholder is related to your directors and executive officers. Please advise or
revise.

December 9, 2025
Page 3
Exhibit 10.1 Stock Incentive Plan, page II-2
6.We note your response to prior comment 17 and reissue in part. Please file your
indemnification agreements with each of your directors and executive officers.
Further, please reconcile the description of Exhibit 10.1 in the exhibit index, which
appears inconsistent with the exhibit title of 2025 Equity Incentive Plan. Additionally,
please advise if Exhibit 10.1 is the same as the “2025 Incentive Award Plan”
referenced on page 62 and revise to clarify. Finally, please revise the Executive and
Director Compensation section to disclose the material terms of Exhibit 10.1 and the
2025 Incentive Award Plan.
Exhibit 107 Filing Fee Table, page II-2
7.We note that you are relying on Rules 457(o) and 457(g). Please revise the
“Maximum Aggregate Offering Price” column of your fee table to reflect the
maximum offering price that you disclose in your prospectus for all offered securities,
including the over-allotment shares to be offered to the public and underwriter
warrants or advise. In this regard, it appears that you used the low end of your price
range of $7.50 instead of the high end range of $9.
Exhibit 5.1 Opinion of Lucosky Brookman LLP, page II-2
8.It appears that the underwriter’s warrants will be governed by New York law. Refer to
Sections 6(e) of the Form of Underwriter’s Warrants and 8.6 of the Initial Form of
Underwriting Agreement, filed as Exhibits 4.2 and 1.1, respectively. If true, please
have New York counsel opine that the warrants are a binding obligation of the
registrant under the law of the jurisdiction governing the warrant agreement, and
update the Experts section as appropriate. Refer to Sections II.B.1.f and II.B.3.b of
Staff Legal Bulletin No. 19.
Part II Information Not Required in Prospectus
Item 16. Exhibits and Financial Statement Schedules, page II-2
9.Please revise to update your exhibit index as follows:
•Please file your articles of incorporation and bylaws or instruments corresponding
thereto as currently in effect. Refer to Items 601(b)(3)(i) and 601(b)(3)(ii) of
Regulation S-K.
•We note that you deleted Exhibit 4.1 Form of Registrant’s Common Stock Share
Certificate. Please revise to file this exhibit.
•Please refile Exhibits 10.3 and 10.4 in the proper text-searchable format. Refer to
Section 5.2.3.6 of the EDGAR Filer Manual (Volume II) EDGAR Filing (Version
75, June 2025) and Item 301 of Regulation S-T.
General
Please revise disclosures throughout the filing to update and/or reconcile apparent
inconsistencies, including the following:
We note your response to prior comment 19 and reissue in part. We note
disclosure on page 59 still provides that Barrett Evans is expected to serve on •10.

December 9, 2025
Page 4
your audit committee. However, this individual is not disclosed on page 55.
Please revise to clarify.
•Reconcile disclosure on the cover page that you are registering 266,666 shares of
Common Stock underlying warrants with disclosure elsewhere that this number is
266,667.
•Reconcile disclosure on page 8 that you intend to apply to have your Common
Stock listed on NYSE with disclosure on page 74 that your Common Stock is
listed on NYSE.
•We note disclosure on page 40 regarding lease obligations of (i) $188 due within
the next 12 months; (ii) $683 due beyond 12 months; (iii) $793 due through 2030;
and (iv) future minimum lease payments of approximately $981. It appears that
these numbers should be in thousands. In this regard, refer to the disclosure on
page F-10 of future lease obligations stated in thousands. Please advise or revise.
•Reconcile references to “articles of incorporation and bylaws,” “amended and
restated certificate of incorporation and amended and restated bylaws,” and
“certificate of incorporation and bylaws” to clarify if these titles refer to the same
documents. Refer to pages 31, 65 and II-2.

            Please contact Jeff Gordon at 202-551-3866 or Kevin Woody at 202-551-3629 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jenny O'Shanick at 202-551-8005 or Anne Parker at 202-551-3611 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Soyoung Lee

CORRESP
 1
 filename1.htm

 Buda
Juice, LLC

 4030
Black Gold Drive

 Dallas,
Texas 75147

 October
17, 2025

 Mr. Jeff
Gordon

 U.S.
Securities & Exchange Commission

 100
F Street, N.E.

 Washington,
D.C. 20549

 Re:
 Buda
 Juice, LLC

 Registration
 Statement on Form S-1

 Filed
 August 27, 2025

 File
 No. 333-289874

 Dear
Mr. Gordon:

 By
letter dated September 23, 2025, the staff (the " Staff ," " you " or " your ") of
the U.S. Securities & Exchange Commission (the " Commission ") provided Buda Juice, LLC (the " Company ,"
" we ," " us " or " our ") with its comments to the Company's Registration Statement
on Form S-1 filed August 27, 2025. We are in receipt of your letter and set forth below are the Company's responses to the Staff's
comments. For your convenience, the comments are listed below, followed by the Company's responses.

 Registration
Statement on Form S-1

 Cover
Page

 1. Please
 revise your prospectus "Subject to Completion" legend to clarify that you and
 the selling stockholder may not sell these securities until the registration statement filed
 with the Securities and Exchange Commission is effective.

 Response :
 We have revised the "Subject to Completion" legend to clarify that the Company and the selling stockholder may not sell
these securities until the registration statement filed with the Securities and Exchange Commission is effective.

 Prospectus
Summary, page 1

 2. Please
 balance your prospectus summary with a discussion of the challenges your products face. For
 example, please discuss your dependence on one customer, which represented approximately
 97% of your net sales of June 30, 2025. Please also address any related risks, including
 expanding the risk factor titled "We depend heavily on third-party retailers...,"
 and update your business section as appropriate.

 Response:
 Recently, we have relied on one customer which has represented approximately 97% of our net sales as of June 30, 2025. We have
begun to diversify our customer base to include some additional national grocery chains to diversify our customer base over the next
year. We have added disclosure on pages 3 of Prospectus Summary section, 42 of MD&A section and 49 of Business section
to disclose our customer dependence. We have also added a risk factor titled "We have depended on a single customer for a substantial
portion of our net sales, and the loss of this customer or a reduction in their purchases could materially and adversely affect our business,
results of operations, and financial condition." Our third-party retailers are the same as our customers and we address the customer
concentration as indicated above.

 Risk
Factors

 Risks
Relating to This Offering, page 28

 3. We
 note that Horatio Lonsdale-Hands, Bryan Herr and Bernard Lucien Nussbaumer serve as directors
 (including chief executive officer and executive chairman) of your company. Please add risk
 factor disclosure regarding their beneficial ownership and voting power after the offering.
 As applicable, discuss their ability to influence matters submitted for stockholder approval,
 including the election of directors, amendment of organizational documents, and approval
 of major corporate transactions. Finally, please discuss potential conflicts of interest
 related to their management roles and shareholdings.

 Response:
 We have added a risk factor regarding the beneficial ownership and voting power of Horatio Lonsdale-Hands, Bryan Herr and Bernard
Lucien Nussbaumer after the offering and the potential consequences.

 Use
of Proceeds, page 32

 4. We
 note disclosure that you intend to use the net proceeds from this offering, in part, to build
 new production facilities in South Carolina and Arizona/Nevada. However, this appears inconsistent
 with other disclosure on page 50 that you intend to lease and build out these facilities.
 Please revise to reconcile these apparent inconsistencies.

 Response:
 The Company will be leasing existing spaces for expansion of the production infrastructure. The Company will need to build out
and furnish the spaces as needed for their production requirements. the space. We have clarified our plans on page 49 of the Registration
Statement.

 Management's
Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 39

 5. We
 note disclosure elsewhere that a single customer accounted for 97% of your revenue in the
 six months ended June 30, 2025. Please revise to discuss any associated trends related to
 your dependence on this customer. Additionally revise your risk factor disclosure regarding
 customer concentration as appropriate to reflect the specific material risks relating to
 this customer, as well as your increased exposure to a single customer (compared with 95%
 and 90% in the fiscal year ended December 31, 2024 and 2023, respectively). Finally, please
 update the section titled "Customer Concentration and Diversification Progress"
 on page 49 to discuss your dependence on this customer.

 Response:
 We have added a risk factor titled "We have depended on a single customer for a substantial portion of our net sales, and
the loss of this customer or a reduction in their purchases could materially and adversely affect our business, results of operations,
and financial condition" and updated the section titled "Customer Concentration and Diversification Progress" on page
49 and added that section in the prospectus summary section as well on page 3.

 Liquidity
and Capital Resources, page 40

 6. Please
 revise to describe your short-term and long-term material cash requirements. Further, please
 revise to discuss your lease commitments disclosed on pages F-9 and F-24. Refer to Item 303
 of Regulation S-K.

 Response:
 We have revised the disclosure on page 40 to more clearly describe the Company's short-term and long-term material cash
requirements and to include a discussion of its lease commitments.

 Business

 Cold
Chain Distribution, page 49

 7. Please
 revise to elaborate on the distribution methods of your products and disclose the material
 terms of your distributor agreements. Refer to Item 101(h)(4)(ii) of Regulation S-K.

 Response:
 We have added a section called "Distribution Methods" on page 51 to elaborate our distribution methods and material
terms of our agreements.

 Intellectual
Property, page 52

 8. Please
 disclose the duration of your trademarks. Refer to Item 101(h)(4)(vii) of Regulation S-K.
 In addition, please reconcile your disclosure elsewhere in the prospectus that you determined
 that Canadian trademark registration was not necessary for your U.S. market development strategy
 and abandoned the application with the disclosure in this section that your trademark portfolio
 includes BUDA JUICE® and RAW ORGANIC REAL® registered in Canada.

 Response:
 We have determined that we do not need Canadian trademarks and we do not intend to retain them. We have revised our disclosure
to include only United States trademarks which are the only relevant ones for our business .

 Regulatory
Compliance, page 53

 9.
 We
 note disclosure on page 60 that you intend for your nominating and corporate governance committee to address various environmental
 matters. Please revise to describe the costs and effects of compliance with environmental laws (federal, state and local), or advise.
 Refer to Item 101(h)(4)(xi) of Regulation S-K.

 Response:
 We have revised our disclosure on page 60 to eliminate the committee's environmental responsibilities. Our waste management
company FCC Environmental services, picks up our natural waste products and they abide by the required environmental laws .

 Seasonality
in Demand and Suppliers, page 53 [F-25]

 10.
 Please
 revise to describe the names of principal suppliers. Refer to Item 101(h)(4)(v) of Regulation S-K. Further, please add risk factor
 disclosure relating to your dependence on a limited number of suppliers. In this regard, we note disclosure elsewhere that two suppliers
 and one supplier represented more than 10% of your total product purchases in the fiscal year ended December 31, 2024 and 2023, respectively.
 Update your business section as appropriate.

 Response:
 We have added a supplier section on page 53 to describe the names of principal suppliers and to discuss the percentage of total
product purchases and dependence on any one supplier. We have also added a risk factor called "We depend on a limited number of
suppliers for our products, and the loss of one or more of these suppliers could disrupt our operations, increase our costs, or otherwise
adversely affect our business" to that effect on page 13.

 Executive
and Director Compensation, page 62

 11. Please
 revise your Summary Compensation table to include compensation for the two most highly compensated
 executive officers other than the principle executive officer, who were serving as executive
 officers at the end of the last completed fiscal year. Refer to Item 402(m)(2)(ii) of Regulation
 S-K. In this regard, we note that you included information for one executive officer, rather
 than two pursuant to this Item. Further, we note disclosure on page 55 that you currently
 have three directors. Please provide compensation information as required by Item 402(r)
 of Regulation S-K for your directors.

 Response:
 Please note that we have two most highly compensated executive officers, including the principle executive officer, who were serving
as executive officers at the end of the last completed fiscal year. There are no other officers who are serving now or at the end
of the last completed fiscal year. For page 55, we currently only have three directors and three director nominees. We have
provided the compensation information as required by Item 402(r) of Regulation S-K for our directors on page 62.

 Certain
Relationships and Related Party Transactions, page 63

 12. Please
 revise to include the related party transaction disclosed on pages F-23 and F-26, or advise.

 Response:
 We have revised the disclosure on page 63 to include the related party transaction disclosed on page F-10 and F-23. Please note
that we have disclosed on page F-26 that we do not have any related party transactions.

 Principal
and Selling Stockholders, page 64

 13. Please
 revise the table to include information for your director nominees. Refer to Item 403(b)
 of Regulation S-K.

 Response:
 We have revised the table to include information for our director nominees on page 64.

 Underwriting,
page 72

 14. Please
 revise the table setting forth the underwriter's compensation to show separately the
 amounts to be paid by the selling stockholder. Refer to Item 508(e) of Regulation S-K.

 Response:
 We have revised the table setting forth the underwriter's compensation to show separately the amounts to be paid by the
selling stockholder.

 Index
to Financial Statements

 Note
15. Subsequent Events, page F-27

 15. We
 note your current disclosure states you evaluated subsequent events through "date of
 issuance." Please revise to disclose the actual date through which subsequent events
 have been evaluated in accordance with ASC 855-10-50-1.

 Response:
 We have revised Note 15, Subsequent Events, in the financial statements to include the actual date.

 16. You
 disclose that in connection with this offering and prior to effectiveness, you intend to
 undertake a statutory conversion from a Texas limited liability company to a Delaware corporation.
 As such, please provide pro forma earnings per share data on the face of the historical financial
 statements given the planned conversion to a C Corporation. Refer to SAB Topic 1:B.2 for
 further information.

 Response:
 We have revised the face of the financial statements to include pro forma earnings per share data.

 Part
II Information Not Required in Prospectus

 Item
16. Exhibits and Financial Statement Schedules, page II-2

 17.
 Please revise your exhibit index to include the following pursuant
to Item 601(b)(10) of Regulation S-K, or tell us why such exhibits are not required:

 ● Agreements
 with your one customer that represented approximately 97% of your net sales of June 30, 2025;

 ● Equity
 and non-equity compensation plan for the non-employee members of the board of directors;

 ● Indemnification
 agreements with each of your directors and executive officers; and

 ● Commercial
 Lease Agreement, as amended.

 Response:
 We do not have any agreements with our one customer that represented approximately 97% of our net sales of June 30, 2025 other
than a non-disclosure agreement. We have added disclosure on page 51 discussing our system on receiving and managing orders.

 We
will file our stock incentive plan and indemnification agreements when complete and we have filed our commercial lease agreements ,
as amended .

 General

 18. Please
 furnish the information required by Item 510 of Regulation S-K in Part I of the prospectus.
 Refer to Item 12A of Form S-1.

 Response:
 We have added the information required by Item 510 of Regulation S-K in Part I of the prospectus on page 66.

 19. Please
 revise disclosures throughout the filing to update and/or reconcile apparent inconsistencies,
 including the following:

 ● We
 note disclosure on page 59 that Barrett Evans is expected to serve on your audit committee.
 However, this individual is not disclosed on page 55. Please revise to clarify.

 ● We
 note disclosures on pages 59 and 60 that your company website is at https://jobairegroup.us/,
 which appears inconsistent with the other disclosure on page 3 that your company website
 is at www.budajuice.com. Please revise to clarify.

 ● We
 note disclosure on the cover page that your common stock has no par value. This appears inconsistent
 with other disclosure in Exhibit 107 that your common stock has a par value of $0.001. Please
 revise to clarify.

 Response:
 We have removed Barret Evans from the Registration Statement. We have corrected the Company's website on pages 59 and 60.
We have added the correct par value of $0.001 to our common stock on the cover page.

 Thank
you for your assistance in reviewing this filing.

 Very
truly yours,

 /s/
 Horatio Lonsdale-Hands

 Horatio
 Lonsdale-Hands

 Chief
 Executive Officer

 Buda
 Juice, LLC

 4030
 Black Gold Drive

 Dallas,
 Texas 75247

September 23, 2025
Horatio Lonsdale-Hands
Chief Executive Officer
Buda Juice, LLC
4030 Black Gold Drive,
Dallas, Texas 75247
Re:Buda Juice, LLC
Registration Statement on Form S-1
Filed August 27, 2025
File No. 333-289874
Dear Horatio Lonsdale-Hands:
            We have reviewed your 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.
Registration Statement on Form S-1
Cover Page
1.Please revise your prospectus "Subject to Completion" legend to clarify that you and
the selling stockholder may not sell these securities until the registration statement
filed with the Securities and Exchange Commission is effective.
Prospectus Summary, page 1
2.Please balance your prospectus summary with a discussion of the challenges your
products face. For example, please discuss your dependence on one customer, which
represented approximately 97% of your net sales of June 30, 2025. Please also address
any related risks, including expanding the risk factor titled "We depend heavily on
third-party retailers...," and update your business section as appropriate.

September 23, 2025
Page 2
Risk Factors
Risks Relating to This Offering, page 28
3.We note that Horatio Lonsdale-Hands, Bryan Herr and Bernard Lucien Nussbaumer
serve as directors (including chief executive officer and executive chairman) of your
company. Please add risk factor disclosure regarding their beneficial ownership and
voting power after the offering. As applicable, discuss their ability to influence
matters submitted for stockholder approval, including the election of directors,
amendment of organizational documents, and approval of major corporate
transactions. Finally, please discuss potential conflicts of interest related to their
management roles and shareholdings.
Use of Proceeds, page 32
4.We note disclosure that you intend to use the net proceeds from this offering, in part,
to build new production facilities in South Carolina and Arizona/Nevada. However,
this appears inconsistent with other disclosure on page 50 that you intend to lease and
build out these facilities. Please revise to reconcile these apparent inconsistencies.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 39
5.We note disclosure elsewhere that a single customer accounted for 97% of your
revenue in the six months ended June 30, 2025. Please revise to discuss any associated
trends related to your dependence on this customer. Additionally revise your risk
factor disclosure regarding customer concentration as appropriate to reflect the
specific material risks relating to this customer, as well as your increased exposure to
a single customer (compared with 95% and 90% in the fiscal year ended December
31, 2024 and 2023, respectively). Finally, please update the section titled "Customer
Concentration and Diversification Progress" on page 49 to discuss your dependence
on this customer.
Liquidity and Capital Resources, page 40
6.Please revise to describe your short-term and long-term material cash requirements.
Further, please revise to discuss your lease commitments disclosed on pages F-9 and
F-24. Refer to Item 303 of Regulation S-K.
Business
Cold Chain Distribution, page 49
7.Please revise to elaborate on the distribution methods of your products and disclose
the material terms of your distributor agreements. Refer to Item 101(h)(4)(ii) of
Regulation S-K.
Intellectual Property, page 52
Please disclose the duration of your trademarks. Refer to Item 101(h)(4)(vii) of
Regulation S-K. In addition, please reconcile your disclosure elsewhere in the
prospectus that you determined that Canadian trademark registration was not
necessary for your U.S. market development strategy and abandoned the application
with the disclosure in this section that your trademark portfolio includes BUDA 8.

September 23, 2025
Page 3
JUICE® and RAW ORGANIC REAL® registered in Canada.
Regulatory Compliance, page 53
9.We note disclosure on page 60 that you intend for your nominating and corporate
governance committee to address various environmental matters. Please revise to
describe the costs and effects of compliance with environmental laws (federal, state
and local), or advise. Refer to Item 101(h)(4)(xi) of Regulation S-K.
Seasonality in Demand and Suppliers, page 53
10.Please revise to describe the names of principal suppliers. Refer to Item 101(h)(4)(v)
of Regulation S-K. Further, please add risk factor disclosure relating to your
dependence on a limited number of suppliers. In this regard, we note disclosure
elsewhere that two suppliers and one supplier represented more than 10% of your total
product purchases in the fiscal year ended December 31, 2024 and 2023, respectively.
Update your business section as appropriate.
Executive and Director Compensation, page 62
11.Please revise your Summary Compensation table to include compensation for the two
most highly compensated executive officers other than the principle executive officer,
who were serving as executive officers at the end of the last completed fiscal year.
Refer to Item 402(m)(2)(ii) of Regulation S-K. In this regard, we note that you
included information for one executive officer, rather than two pursuant to this Item.
Further, we note disclosure on page 55 that you currently have three directors. Please
provide compensation information as required by Item 402(r) of Regulation S-K for
your directors.
Certain Relationships and Related Party Transactions, page 63
12.Please revise to include the related party transaction disclosed on pages F-23 and F-
26, or advise.
Principal and Selling Stockholders, page 64
13.Please revise the table to include information for your director nominees. Refer to
Item 403(b) of Regulation S-K.
Underwriting, page 72
14.Please revise the table setting forth the underwriter’s compensation to show separately
the amounts to be paid by the selling stockholder. Refer to Item 508(e) of Regulation
S-K.
Index to Financial Statements
Note 15. Subsequent Events, page F-27
15.We note your current disclosure states you evaluated subsequent events through “date
of issuance.” Please revise to disclose the actual date through which subsequent
events have been evaluated in accordance with ASC 855-10-50-1.

September 23, 2025
Page 4
16.You disclose that in connection with this offering and prior to effectiveness, you
intend to undertake a statutory conversion from a Texas limited liability company to a
Delaware corporation. As such, please provide pro forma earnings per share data on
the face of the historical financial statements given the planned conversion to a C
Corporation. Refer to SAB Topic 1:B.2 for further information.
Part II Information Not Required in Prospectus
Item 16. Exhibits and Financial Statement Schedules, page II-2
17.Please revise your exhibit index to include the following pursuant to Item 601(b)(10)
of Regulation S-K, or tell us why such exhibits are not required:
•Agreements with your one customer that represented approximately 97% of your
net sales of June 30, 2025;
•Equity and non-equity compensation plan for the non-employee members of the
board of directors;
•Indemnification agreements with each of your directors and executive officers;
and
•Commercial Lease Agreement, as amended.
General
18.Please furnish the information required by Item 510 of Regulation S-K in Part I of the
prospectus. Refer to Item 12A of Form S-1.
19.Please revise disclosures throughout the filing to update and/or reconcile apparent
inconsistencies, including the following:
•We note disclosure on page 59 that Barrett Evans is expected to serve on your
audit committee. However, this individual is not disclosed on page 55. Please
revise to clarify.
•We note disclosures on pages 59 and 60 that your company website is at
https://jobairegroup.us/, which appears inconsistent with the other disclosure on
page 3 that your company website is at www.budajuice.com. Please revise to
clarify.
•We note disclosure on the cover page that your common stock has no par value.
This appears inconsistent with other disclosure in Exhibit 107 that your common
stock has a par value of $0.001. Please revise to clarify.

September 23, 2025
Page 5
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Jeff Gordon at 202-551-3866 or Kevin Woody at 202-551-3629 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jenny O'Shanick at 202-551-8005 or Anne Parker at 202-551-3611 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:Soyoung Lee