SecProbe.io

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 Stifel, Nicolaus & Company, Incorporated

 787 Seventh Avenue, 11th Floor
New York, New York 10019

 William Blair & Company, L.L.C.

 150 North Riverside Plaza

 Chicago, Illinois 60606

 December 4, 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

 Attn: Peter McPhun, Jennifer Monick, Ruairi Regan, and Pamela Long

 Re: Cardinal Infrastructure Group Inc.

 Registration Statement on Form S-1, as amended

 Filed October 14, 2025

 File No. 333-290850

 Acceleration Request

 Requested Date: December 9, 2025

 Requested Time: 3:00 P.M. Eastern Time

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the Securities Act
of 1933, as amended (the "Securities Act"), we, as the representatives of the several underwriters (the "Representatives"),
hereby join in the request of Cardinal Infrastructure Group Inc., a Delaware corporation (the "Company"), that the effective
date of the above-referenced Registration Statement on Form S-1 (the "Registration Statement") be accelerated so that it will
be declared effective at 3:00 p.m. Eastern Time, on December 9, 2025, or as soon thereafter as practicable, or at such other time
thereafter as the Company or its outside counsel, Willkie Farr & Gallagher LLP, may request by telephone to the staff of the Securities
and Exchange Commission.

 Pursuant to Rule 460 under the Securities Act,
we, as the Representatives, wish to advise you that we will take reasonable steps to secure adequate distribution of the preliminary prospectus
to underwriters, dealers, institutions and others prior to the requested effective time of the Registration Statement.

 We, the undersigned Representatives, hereby represent
that we are in compliance and will comply, and we have been informed by the other participating underwriters that they are in compliance
and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the offering
pursuant to the Registration Statement and preliminary prospectus.

 [ Signature Page Follows ]

 Very truly yours,

 Stifel, Nicolaus & Company, Incorporated

 William Blair & Company, L.L.C.,

 As Representatives of the several Underwriters

 STIFEL, NICOLAUS & COMPANY, INCORPORATED

 By:
 /s/ Craig DeDomenico

 Name:
 Craig DeDomenico

 Title:
 Managing Director

 WILLIAM BLAIR & COMPANY, L.L.C.

 By:
 /s/ Zach Dombrowski

 Name:
 Zach Dombrowski

 Title:
 Managing Director

 [ Signature Page to Underwriters' Acceleration Request Letter ]

CORRESP
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 CARDINAL INFRASTRUCTURE GROUP INC.

 100 E. Six Forks Road, #300

 Raleigh, North Carolina 27609

 December 4, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.

 Washington, D.C. 20549-6010

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

 Re:
 Cardinal Infrastructure Group Inc.

 Registration Statement on Form S-1 (File No. 333-290850)

 Ladies and Gentlemen:

 In accordance with Rule 461
of under the Securities Act of 1933, as amended, we hereby request acceleration of the effective date of the Registration Statement on
Form S-1, as amended (File No. 333-290850) (the " Registration Statement ") of Cardinal Infrastructure Group Inc.
(the " Company "). We respectfully request that the Registration Statement become effective as of 3:00 p.m.,
Eastern Time, on December 9, 2025, or at such later time as the Company or its counsel may orally request via telephone call to
the staff of the Division of Corporation Finance of the Securities and Exchange Commission. Once the Registration Statement has
been declared effective, please orally confirm that event with our counsel, Willkie Farr & Gallagher LLP, by calling Edward S. Best
at (312) 728-9000.

 We understand that the staff
of the Securities and Exchange Commission will consider this request as confirmation by the Company that it is aware of its responsibilities
under the federal securities laws as they relate to the issuance of the securities covered by the Registration Statement. If you have
any questions regarding the foregoing, please contact Edward S. Best of Willkie Farr & Gallagher LLP at the number set forth above.

 Thank you for your assistance
in this matter.

 [ Signature Page Follows ]

 December 4, 2025

 Page 2

 Very truly yours,

 CARDINAL INFRASTRUCTURE GROUP INC.

 By:
 /s/ Jeremy Spivey

 Name:
 Jeremy Spivey

 Title:
 Chief Executive Officer

 cc:
 (via email)

 Mike Rowe, Chief Financial Officer, Cardinal Infrastructure Group Inc.

 Tiffany Gidley, General Counsel, Cardinal Infrastructure Group Inc.

 Edward S. Best, Esq., Willkie Farr & Gallagher LLP

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 300 North LaSalle Dr.
Chicago, IL 60654-3406

 Direct Tel: 312 728 9158

 Mobile: 312 927 0860

 December 3, 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.

 Amendment No. 1 to Registration
Statement on Form S-1 Filed November 20, 2025

 Amendment No. 2 to Registration
Statement on Form S-1 Filed December 1, 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 December 2, 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
November 20, 2025 and December 1, 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.

 Amendment No. 2 to Form S-1 filed December 1, 2025

 General

 1. We note your disclosure on page 108 that directors, director
nominees and executive officers, as a group, will own 55.7% of the voting power of the combined company, or 52.8% if the over-allotment
option is exercised. With a view toward disclosure, please tell us whether you will be a "controlled company" within the meaning
of the corporate governance standards of the Nasdaq rules, and if so, please disclose your status and whether you intend to rely on exemptions
from certain corporate governance requirements available to controlled companies under Nasdaq rules.

 Response : The Company acknowledges
the Staff's comment and respectfully advises the Staff that the Company is not expected to be a "controlled company"
under Nasdaq Listing Rule 5615(c) following the offering as no individual, "group" (as defined under Nasdaq Listing Rule 5615(c)),
or other company is expected to hold more than 50% of the voting power for the election of the Company's directors following the
offering. While, based upon an assumed initial public offering price of $21.00 per share (which is the midpoint of the price range set
forth on the cover page of Registration Statement) the directors, director nominees and executive officers collectively will own more
than 50% of the voting power of the Company, such persons do not have any agreement to act as a voting group. Accordingly, the Company
will not be a "controlled company" within the meaning of the corporate governance standards of the Nasdaq rules and, therefore,
will not rely on exemptions from certain corporate governance requirements available to controlled companies thereunder. Company additionally
notes that the Form S-1 contains a risk factor disclosing that upon consummation of the offering, the Continuing Equity Holders (which
includes members of the Company's management and board of directors), will control, in the aggregate, approximately 63.9% of the
voting power of all classes of the Company's voting securities and, as a result, will continue to exercise significant influence
over matters on which holders of the Company's common stock are entitled to vote. See " Risk Factors-Risks Related
to this Offering and Ownership of our Class A Common Stock-The Continuing Equity Holders will continue to have significant
influence over us after this offering, including control over decisions that require the approval of stockholders ."

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Hamburg Houston London Los Angeles

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 We hope the foregoing is responsive
to your comments and are available to discuss with you at your earliest convenience. If you have any questions, 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.

December 2, 2025
Jeremy Spivey
Chief Executive Officer
Cardinal Infrastructure Group Inc.
100 E. Six Forks Road, #300
Raleigh, North Carolina 27609
Re:Cardinal Infrastructure Group Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed November 20, 2025
Amendment No. 2 to Registration Statement on Form S-1
Filed December 1, 2025
File No. 333-290850
Dear Jeremy Spivey:
            We have reviewed the amendments to your registration statement and have the
following comment.
            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.
Amendment No. 2 to Form S-1 filed December 1, 2025
General
1.We note your disclosure on page 108 that directors, director nominees and executive
officers, as a group, will own 55.7% of the voting power of the combined company, or
52.8% if the over-allotment option is exercised. With a view toward disclosure, please
tell us whether you will be a "controlled company" within the meaning of the
corporate governance standards of the Nasdaq rules, and if so, please disclose your
status and whether you intend to rely on exemptions from certain corporate
governance requirements available to controlled companies under Nasdaq rules.
            Please contact Peter McPhun at 202-551-3581 or Jennifer Monick at 202-551-3295 if

December 2, 2025
Page 2
you have questions regarding comments on the financial statements and related
matters. Please contact Ruairi Regan at 202-551-3269 or Pamela Long at 202-551-3765 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Edward Best, Esq.

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.

November 18, 2025
Jeremy Spivey
Chief Executive Officer
Cardinal Infrastructure Group Inc.
100 E. Six Forks Road, #300
Raleigh, North Carolina 27609
Re:Cardinal Infrastructure Group Inc.
Registration Statement on Form S-1
Filed October 14, 2025
File No. 333-290850
Amended Draft Registration Statement on Form S-1
Submitted September 29, 2025
CIK No. 0002079999
Dear Jeremy Spivey:
            We have reviewed your registration statement and have the following comment.
            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 filed October 14, 2025
Management Discussion and Analysis of Financial Condition and Results of Operations
Capital Expenditures, page 86
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 1.

November 18, 2025
Page 2
equipment on your balance sheets. If yes, please explain the basis for this accounting
treatment and provide the authoritative accounting literature management relied upon.
            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 Peter McPhun at 202-551-3581 or Jennifer Monick at 202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please contact Ruairi Regan at 202-551-3269 or Pamela Long at 202-551-3765 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Edward Best, Esq.

September 24, 2025
Jeremy Spivey
Chief Executive Officer
Civil Infrastructure Group Inc.
100 E. Six Forks Road, #300
Raleigh, North Carolina 27609
Re:Civil Infrastructure Group Inc.
Amended Draft Registration Statement on Form S-1
Submitted September 16, 2025
CIK No. 0002079999
Dear Jeremy Spivey:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement and non-public draft submissions on EDGAR. 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 the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in
our September 8, 2025 letter.
Amendment to Draft Registration Statement on Form S-1 filed September 16, 2025
Summary Historical and Pro Forma Financial and Other Data, page 17
1.We note your response to our prior comment 7 and your calculations of gross profit
and adjusted gross profit. Please ensure that the gross profit amounts on page 18 are
consistent with the amounts on page 76.
Our principal asset upon completion of the offering ..., page 38
Please revise disclosure in this risk factor for consistency with disclosure on page 116
regarding Cardinal's distributions to its members. Specifically, clarify which amounts
will be distributed on a pro rata basis among you and the Continuing Equity Holders 2.

September 24, 2025
Page 2
and which will be distributed on a non-pro rata basis. In this regard, we note that
payments under the Tax Receivable Agreement are grouped together with both pro
rata taxable income allocations and non-pro rata operating expenses as described at
the bottom of page 38. In addition, in connection with prior comment 18 and your
revised disclosure on page 116, please also clarify if true that the receipt by the
Continuing Equity Holders of a portion of the pro rata distribution from Cardinal in
respect of the Tax Receivable Agreement does not impact or offset the amount of the
payment that you will be required to make to Continuing Equity Holders under the
Tax Receivable Agreement.
Capitalization, page 55
3.We note you have populated the first column in your capitalization table. Please revise
the amount of total capitalization for accuracy, or advise.
Index to Financial Statements, page F-1
4.We note your response to our prior comment 19. We further note your reference to a
$40 million acquisition of an unidentified entity on page 53. Please tell us if you
consider this newly referenced acquisition to be probable, and tell us how you made
your determination. To the extent you determine this newly reference acquisition to be
probable, please tell us how such acquisition impacts your significance tests.
Reference is made to Rule 3-05 and Article 11 of Regulation S-X.
            Please contact Peter McPhun at 202-551-3581 or Jennifer Monick at 202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please contact Ruairi Regan at 202-551-3269 or Pamela Long at 202-551-3765 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Edward Best, Esq.

September 8, 2025
Jeremy Spivey
Chief Executive Officer
Civil Infrastructure Group Inc.
100 E. Six Forks Road, #300
Raleigh, North Carolina 27609
Re:Civil Infrastructure Group Inc.
Draft Registration Statement on Form S-1
Submitted August 11, 2025
CIK No. 0002079999
Dear Jeremy Spivey:
            We have reviewed your draft registration statement and have the following comments.
            Please respond to this letter by providing the requested information and either
submitting an amended draft registration statement or publicly filing your registration
statement and non-public draft submissions on EDGAR. 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 the information you provide in response to this letter and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form S-1
Use of Proceeds, page 53
We note disclosure in the third paragraph that Cardinal will use net proceeds to repay
borrowings under the Existing Credit Facility and the Equipment Facility, as well as
disclosure in the fifth paragraph that if the underwriters exercise in full their option to
purchase additional shares of Class A Common Stock, Cardinal intends to use such
additional net proceeds for general corporate purposes, which may include "funding
for acquisitions, working capital requirements, capital expenditures and the
repayment, refinancing, redemption or repurchase of indebtedness or other securities."
Please revise to provide the interest rate and maturity of the Existing Credit Facility,
the Equipment Facility and any other debt that Cardinal may repay with any offering
proceeds, and to the extent that such facilities or other debt were incurred within one 1.

September 8, 2025
Page 2
year, please describe the use of the proceeds of such debt. Refer to Instruction 4 of
Item 504 of Regulation S-K. Please also reconcile disclosure in the fifth paragraph
that you intend to contribute all of the additional net proceeds from the exercise of the
over-allotment option to Cardinal in exchange for an additional LLC Units with the
statement in the second paragraph that you will use proceeds from the exercise of the
over-allotment option to purchase LLC Units from the Continuing Equity Holders.
2.Please reconcile your disclosure in this section and on page 13 in the summary that
you intend to purchase newly issued LLC Units directly from Civil Infrastructure with
your disclosure elsewhere in the prospectus that you will purchase such LLC interests
from Cardinal.
Unaudited Pro Forma Condensed Consolidated Financial Information, page 58
3.We refer you to your disclosure on page F-27. It appears that the Class B and Class C
Units have a contingent right to require redemption, and that as of December 31,
2024, the probable condition of a change in control has not been met. Please clarify
for us if this condition will be met as part of the reorganization transactions or the
offering, and how you made your determination. To the extent this condition will be
met as part of the reorganization transactions or the offering, please tell us what
consideration you gave to reflecting the impact, if any, in your pro forma financial
information. Reference is made to Article 11 of Regulation S-X.
4.Please revise your pro forma financial information to disaggregate your adjustments
column into a separate column reflecting the reorganization and a separate column
reflecting the offering. Reference is made to Rule 11-02(b)(4)(i) of Regulation S-X.
This comment also applies to your capitalization table.
Management's Discussion & Analysis, page 69
5.We note your disclosure regarding your robust backlog of approximately
$846.0 million at December 31, 2024 compared to a backlog of approximately
$520.0 million for the year ended December 31, 2023. We also note your disclosure
that as of June 30, 2025, your backlog was approximately $968.0 million. Please
revise to explain the significant increases in your revenue backlog, and provide
additional information where material to understanding backlog. For example,
disclose the proportions of backlog which are attributable to signed private
contracts, low bidder on public sector contracts and verbal and other commitments.
Similarly, provide the proportions which are derived from fixed-unit price contracts
and lump sum contracts. We further note your disclosure that the contracts in backlog
are typically completed in six to 36 months. Please discuss management's expectations
regarding when the disclosed backlog will convert to revenue including the dollar
amount expected to be filled within the current year. Finally, please reconcile your
disclosure regarding backlog from verbal and other commitments with your disclosure
on page 23 that it is generally very difficult to predict whether and when new
contracts will be offered for tender, as our contracts frequently involve a lengthy and
complex design and bidding process.

September 8, 2025
Page 3
Management's Discussion and Analysis of Financial Condition and Results of Operations,
page 69
6.We note your disclosure that you generally are required to provide various types of
surety and payment bond for certain contracts. Please tell us what consideration you
gave to disclosing quantitative information about your obligations related to these
bonds. Reference is made to Item 303 of Regulation S-K.
Non-GAAP Financial Measure, page 72
7.We note your presentation of Gross Profit, which you identify as a non-GAAP
measure. Please revise to reconcile gross profit to the most directly comparable
GAAP measure. Please refer to Item 10(e) of Regulation S-K.
Results of Operations, page 73
8.We note you have identified multiple factors that impact your operating results but it
does not appear that you have separately quantified each factor. For example purposes
only, you state that the increase in revenues was primarily driven by a combination
of organic growth in your existing markets and new markets along with acquisitions
made in 2023 and prior years. When there are multiple factors impacting your
operating results, please revise your disclosures to separately quantify the impact from
each factor.
9.You state the increase in net interest expense was primarily driven by higher debt
resulting from the acquisition of Purcell in 2024. Additionally, you state increase in
other expenses was driven by refinancing costs and transaction costs related to your
acquisitions of Monroe Roadways, Inc. and Purcell Construction, Inc. incurred in
2024. Based on disclosures elsewhere in your filing, it appears the acquisition of
Purcell occurred in 2025 and the acquisition of Monroe Roadways occurred in 2023.
Please revise, or advise.
Credit Facilities, Debt and Other Capital, page 75
10.Please describe clearly the material terms of your finance lease obligations referenced
in the pro-forma balance sheet on page 62 and in Cardinal's audited financial
statements. Also, file each of the agreements governing your material indebtedness
including your October 21, 2024 agreement as exhibits.
Business, page 81
11.Please expand your disclosure regarding your markets and customers to describe
clearly your revenue-generating activities including key projects in which you are
currently engaged and the status of development efforts for such projects. Also,
describe the extent to which your business is or may be seasonal. Refer to Item
101(c)(1) of Regulation S-K.
We note your disclosure in your risk factors and elsewhere regarding third party
suppliers to provide substantially all of the materials (including aggregates, cement,
asphalt, concrete, steel, oil and fuel) for your contracts and third party subcontractors
to perform some of the work on many of your projects. Please describe your
arrangements with suppliers and subcontractors. Also, please file material contracts 12.

September 8, 2025
Page 4
with suppliers or contractors as exhibits to your registration statement pursuant to
Item 601(b)(10) of regulation S-K.
13.Please clarify the types and terms of contracts you use. We note disclosure on page 86
regarding fixed unit price contracts under which you would provide the resources
required to complete a contract for a fixed price as well as emergency contracts
arranged on a "cost-plus basis." We also note disclosure on page 21 referring to fixed
unit price and "lump sum" contracts and on page F-22 regarding "time and material"
billed contracts.
Properties, page 89
14.Please expand your disclosure in this section to provide, if material, a general
description and location of the properties you own and lease and describe briefly how
held. Refer to Item 102 of Regulation S-K. We note your disclosure in footnote 7 on
page F-24.
Certain Relationships and Related Party Transactions, page 106
15.Please revise your description of related party transactions with Envision, Wellfield
and Park to clarify the nature of Mr. Spivey's position or relationship with or
ownership of these entities. Please see Item 404(a)(2) of Regulation S-K.
16.We note your disclosure on page 106 that the following are summaries of certain
provisions of our agreements with related persons and are qualified in their entirety by
reference to all the provisions of such agreements. Note that information in the
prospectus may not be qualified by information outside of the prospectus other than as
stated in Rule 411(a). Please revise.
17.Please identify which Continuing Equity Holders are the related parties that are party
to each of the Exchange Agreement, the Cardinal Operating Agreement, Tax
Receivable Agreement and the Registration Rights Agreement. Refer to Item
404(a)(1) of Regulation S-K.
Cardinal Operating Agreement, page 107
18.In the second paragraph on page 108, please clarify whether the non-pro rata
payments that you intend to cause Cardinal to make to reimburse you for your
corporate and overhead expenses include an amount in respect of your payments
under the Tax Receivable Agreement. If not, please clarify whether distributions from
Cardinal with respect to payments you are required to make under the Tax Receivable
Agreement will be pro rata among all of the holders of LLC Units such that the
Continuing Equity Holders will receive both pro rata Tax Receivable Agreement
distributions from Cardinal and payments from you under the Tax Receivable
Agreement.
Index to Financial Statements, page F-1
19.In your subsequent events disclosure on page F-30, you disclose that you acquired
Purcell Companies and a turn-key site work contracting business during 2025. Please
tell us if you determined such acquisitions are significant under Rule 3-05. Please
provide your significance calculations within your response.

September 8, 2025
Page 5
Notes to the Consolidated Financial Statements
14. VIE
Unconsolidated VIE's, page F-29
20.We note your reference on page F-29 to the inclusion of a table that summarizes select
information related to variable interests in entities for which the Company is not the
primary beneficiary as of December 31, 2024 and 2023. Such table was not included
in the filing. Please revise to include the table, or advise.
21.Please revise to include disclosure of your maximum exposure to loss as a result of
your involvement with your unconsolidated VIEs, including how the maximum
exposure is determined and the significant sources of your exposure to the VIE as
required by ASC 810-10-50-4b, or tell us how you determined such disclosure is not
required.
Signatures, page II-5
22.The signatures should identify each capacity in which the offering statement is being
signed including the principal accounting officer and a majority of your board of
directors. Please revise.
Exhibits
23.We note your former auditor refers to Item 11 of Form S-1 within exhibit 16.1;
however, we are unable to locate a section labeled Item 11 within your filing. Please
have your former auditor revise their letter to refer to the section "Changes in
Independent Registered Public Accounting Firm" or advise.
24.We note your disclosure on page 107 that the form of Exchange Agreement is filed as
an exhibit to the registration statement; however,that exhibit does not appear to be
included in the exhibit index on page II-3. Please revise.
General
25.Please supplementally provide us with copies of all written communications, as
defined in Rule 405 under the Securities Act, that you, or anyone authorized to do so
on your behalf, present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not they retain copies of the communications.

September 8, 2025
Page 6
            Please contact Peter McPhun at 202-551-3581 or Jennifer Monick at 202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please contact Ruairi James Regan at 202-551-3269 or Pamela Long at 202-551-
3765 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Edward Best, Esq.