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                               December 6, 2023

       Morgan Callagy
       Co-Chief Executive Officer
       Revelstone Capital Acquisition Corp.
       14350 Myford Road
       Irvine, CA 92606

                                                        Re: Revelstone Capital
Acquisition Corp.
                                                            Amendment No. 3 to
Registration Statement on Form S-4
                                                            Filed November 21,
2023
                                                            File No. 333-274049

       Dear Morgan Callagy:

            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 November 16,
2023 letter.

       Amendment No. 3 to the Registration Statement on Form S-4

       Risk Factors, page 37

   1.                                                   We note your disclosure
on page 184 that, assuming the closing of the Business
                                                        Combination, existing
working capital, further advances and debt instruments, and
                                                        anticipated cash flow
are not currently expected to be adequate to fund operations over the
                                                        next 12 months at
planned operating levels. We also note your disclosure that
                                                        you expect the need for
additional capital and renegotiation, extension or refinancing of
                                                        existing debt to fund
operations over the next 12 months. Please revise your risk factor
                                                        titled "There is
substantial doubt about Set Jet   s ability to continue as a going concern. Set
                                                        Jet may need additional
financing to execute its business plan, to fund its operations and
                                                        to continue as a going
concern" to include this information.
 Morgan Callagy
FirstName
RevelstoneLastNameMorgan     Callagy
           Capital Acquisition Corp.
Comapany6,
December  NameRevelstone
             2023           Capital Acquisition Corp.
December
Page 2    6, 2023 Page 2
FirstName LastName
Certain Set Jet Projected Financial Information, page 104

2.       We note that you have removed from this section disclosures regarding
Adjusted EBITDA
         (Loss). Please tell us why you removed such disclosure. As part of
your response, please
         tell us whether the information regarding historical and projected
Adjusted EBITDA
         (Loss) was used or relied upon by the Revelstone board of directors in
determining to
         approve the business combination, or by the fairness advisor in making
the fairness
         determination.
Certain Set Jet Relationships and Related Party Transactions, page 186

3.       We note your response to prior comment 6 that although Set Jet has
entered into aircraft
         charter agreements with other parties, none of these parties fall
within the definition of
            related person    under Item 404 of Regulation S-K. Please provide
the disclosure set forth
         in Item 404 of Regulation S-K with respect to the aircraft charter
agreement between Set
         Jet and Maine Aviation Aircraft Charter, LLC referenced in the select
services agreement
         filed as Exhibit 10.41, or provide your analysis as to why such
disclosure is not
         required. In that regard, we note that Item 404 requires disclosure
with respect to certain
         transactions in which any related person had or will have a direct or
indirect material
         interest.
       Please contact Robert Babula at 202-551-3339 or Jenifer Gallagher at
202-551-3706 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Michael Purcell at 202-551-5351 or Laura Nicholson at 202-551-3584 with
any other
questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Energy
& Transportation
cc:      Alex Weniger-Araujo