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                             October 20, 2022

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

                                                        Re: CaliberCos Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed September 29,
2022
                                                            File No. 333-27657

       Dear John Loeffler:

              We have reviewed your registration statement 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 registration
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 registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form S-1

       Cover page

   1.                                                   The facing page of the
registration statement indicates that this is "Amendment No. 2" to
                                                        the registration
statement. Please ensure that the amendment that you file in response to
                                                        our comments correctly
identifies itself as "Amendment No. 1."
       Management's Discussion and Analysis ...
       Trends, page 41

   2.                                                   We note your response
to comment 3 of our letter and reissue in part. Please expand your
                                                        disclosure further to
elaborate on how increased interest rates applicable to you or your
                                                        funds impacts your
results of operations, including without limitation:
 John Loeffler, II
FirstName
CaliberCosLastNameJohn Loeffler, II
           Inc.
Comapany
October 20,NameCaliberCos
            2022          Inc.
October
Page 2 20, 2022 Page 2
FirstName LastName
                Any expected changes to your product and services mix,
including specific
              challenges or opportunities a rising interest rate environment
presents in the near-
              term to your construction and asset purchases, sales, and rental
operations, and the
              impact that ongoing supply chain challenges or disruptions may
have on your ability
              to make these changes;
                Any expected decreases in project sales, given increased cost
of financing; and
                Expected impacts to your short-term funding costs, including
working capital for
              inventory and labor costs
Business, page 60

3.       We note your response to comment 7 of our letter and reissue in part.
We note that your
         operations are organized into your three reportable segments. Please
clarify which funds
         you perform these activities for, identifying the funds, clarifying
the operations of the
         funds and your services to them, and breaking them apart by segment.
Please clarify the
         nature of the interest you hold in each fund and how you benefit from
them. We note that
         you cite direct membership or partnership interests in the funds,
however, you should
         clearly state whether you receive revenue from any funds in this
capacity (as opposed to
         fund management, development and brokerage activities reflected in
your reportable
         segments), and identify those funds and describe your interest in
them. In addition, please
         clarify that the column, "Caliber Revenues" is presented before
eliminations, and please
         include consolidated revenues in order to balance the disclosure. Also
clarify how the
         column "Fund Revenues" is determined. If you do not believe this
information is material
         to understanding your business, please explain why, given that a
significant portion of
         your consolidated revenue is from consolidated funds rather than the
operations
         underlying your three reportable segments.
Exhibit Index, page II-3

4.       We note your response to prior comment 8 that the requested agreement
has been filed as
         an exhibit. If you are incorporating this and other exhibits by
reference to other filings
         you should note this in your exhibit index, rather than stating that
the exhibits are
         "previously filed." You must also include an active hyperlink to
exhibits incorporated by
         reference or filed with the registration statement. Please see Item
601(a)(2) of Regulation
         S-K.
        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.
 John Loeffler, II
CaliberCos Inc.
October 20, 2022
Page 3

        You may contact Frank Knapp at 202-551-3805 or Shannon Menjivar at
202-551-3856 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Stacie Gorman at Stacie Gorman 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
October 20, 2022 Page 3
cc:       Thomas J. Poletti. Esq.
FirstName LastName