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                             June 17, 2020

       John Loeffler, II
       Chief Executive Officer
       CaliberCos Inc.
       8901 E. Mountain View Rd
       Ste 150
       Scottsdale, AZ 85258

                                                        Re: CaliberCos Inc.
                                                            Offering Statement
on Form 1-A
                                                            Post-qualification
Amendment No. 1
                                                            Filed May 27, 2020
                                                            File No. 024-11016

       Dear Mr. Loeffler:

              We have reviewed your amendment and have the following comments.
In some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to this letter by amending your offering statement
and providing the
       requested information. If you do not believe our comments apply 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 offering statement and
the information you
       provide in response to these comments, we may have additional comments.

       Offering Statement on Form 1-A Post-qualification Amendment No. 1

       Incorporation by Reference of Offering Circular, page 1

   1.                                                   We note that you are
seeking to incorporate information by reference. Please note that
                                                        General Instruction III
of Form 1-A limits the amount of information that can be
                                                        incorporated by
reference and further requires that all descriptions of where information
                                                        incorporated by
reference can be found must be accompanied by a hyperlink to the
                                                        incorporated document
on EDGAR. Please revise your post-effective amendment to
                                                        comply with the
requirements set forth in this instruction.
       Trends Affecting Our Business, page 3

   2.                                                   We note your disclosure
that the majority of your business is located in Arizona. If
 John Loeffler, II
CaliberCos Inc.
June 17, 2020
Page 2
       material, please revise your disclosure to address the recent
significant increase of
       COVID-19 in Arizona and any additional impact of this increase on your
business
       operations.
General

3.     Please note the financial statement updating requirements of paragraph
(c)(1) Part F/S of
       Form 1-A.
        We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.

        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.

       Please contact Stacie Gorman at 202-551-3585 or Pam Long at 202-551-3765
with any
other questions.



                                                              Sincerely,
FirstName LastNameJohn Loeffler, II
                                                              Division of
Corporation Finance
Comapany NameCaliberCos Inc.
                                                              Office of Real
Estate & Construction
June 17, 2020 Page 2
cc:       Thomas Poletti, Esq.
FirstName LastName