November 7, 2024 Jeptha E. Larkin Chief Financial Officer Capital City Bank Group, Inc. 217 North Monroe Street Tallahassee, FL 32301 Re: Capital City Bank Group, Inc. Amendment No. 2 to Form 10-K for Fiscal Year Ended December 31, 2023 File No. 000-13358 Dear Jeptha E. Larkin: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Finance