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                                December 30, 2022

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

                                                        Re: CaliberCos Inc.
                                                            Amendment No. 3 to
Registration Statement on Form S-1
                                                            Filed December 14,
2022
                                                            File No. 333-27657

       Dear John Loeffler:

              We have reviewed your amended registration statement and have the
following
       comment. In our comment, 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 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 comment, we may have additional comments.

       Amendment No. 3 to Registration Statement on Form S-1

       Risk Factors, page 14

   1.                                                   We note recent
instances of extreme stock price run-ups followed by rapid price declines
                                                        and stock price
volatility seemingly unrelated to company performance following a
                                                        number of recent
initial public offerings, particularly among companies with relatively
                                                        smaller public floats.
Revise to include a risk factor, separate from your more general
                                                        volatility risk on page
27, addressing the potential for rapid and substantial price volatility
                                                        and any known factors
particular to your offering that may add to this risk and discuss the
                                                        risks to investors when
investing in stock where the price is changing rapidly. Clearly
                                                        state that such
volatility, including any stock-run up, may be unrelated to your actual or
                                                        expected operating
performance and financial condition or prospects, making it difficult
 John Loeffler, II
CaliberCos Inc.
December 30, 2022
Page 2
      for prospective investors to assess the rapidly changing value of your
stock.
       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 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
December 30, 2022 Page 2
cc:       Thomas J. Poletti. Esq.
FirstName LastName