July 1, 2019

Via E-mail
John C. Loeffler, II
Chief Executive Officer and Chairman of the Board
CaliberCos Inc.
8901 E. Mountain View Road
Suite 150
Scottsdale, AZ 85258

       Re:     CaliberCos Inc.
               Offering Statement on Form 1-A
               Filed June 13, 2019
               File No. 024-11016

Dear Mr. Loeffler:

        We have reviewed your offering 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 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.

Exclusive forum for adjudication of disputes, page 64

1.     We note that your forum selection provision identifies the Court of
Chancery of the State of
       Delaware as the exclusive forum for certain litigation, including any
"derivative action." You
       state that this provision is intended to apply to claims under the
federal securities laws. Please
       note that Section 27 of the Exchange Act creates exclusive federal
jurisdiction over all suits
       brought to enforce any duty or liability created by the Exchange Act or
the rules and
       regulations thereunder, and Section 22 of the Securities Act creates
concurrent jurisdiction
       for federal and state courts over all suits brought to enforce any duty
or liability created by
       the Securities Act or the rules and regulations thereunder. If this
provision does not apply to
       actions arising under the Securities Act or Exchange Act, please also
ensure that the
       exclusive forum provision in the governing documents states this
clearly, or tell us how you
       will inform investors in future filings that the provision does not
apply to any actions arising
       under the Securities Act or Exchange Act.
 John C. Loeffler, II
CaliberCos Inc.
July 1, 2019
Page 2

        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. We also remind you that, following qualification of your
Form 1-A, Rule 257
of Regulation A requires you to file periodic and current reports, including a
Form 1-K which
will be due within 120 calendar days after the end of the fiscal year covered
by the report.

        You may contact Kristi Marrone at (202)551-3429 or Kevin Woody,
Accounting Branch
Chief, at (202)551-3629 if you have questions regarding comments on the
financial statements
and related matters. Please contact Stacie Gorman at (202)551-3585 or me at
(202)551-3215
with any other questions.


                                                             Sincerely,

                                                             /s/ Kim McManus

                                                             Kim McManus
                                                             Senior Counsel
                                                             Office of Real
Estate and
                                                             Commodities
cc: Thomas Poletti, Esq. (via e-mail)