July 17, 2019

Charles A. Bacon, III
Chief Executive Officer
Limbach Holdings, Inc.
1251 Waterfront Place, Suite 201
Pittsburgh, Pennsylvania 15222

       Re: Limbach Holdings, Inc.
           Registration Statement on Form S-3
           Filed June 27, 2019
           File No. 333-232406

Dear Mr. Bacon:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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.

Form S-3 filed June 27, 2019

General

1.     With respect to Mr. McCann's appointment as Co-Chief Operating Officer
on December
       5, 2018, the Item 5.02 Form 8-K reporting this event was filed on
December 21, 2019. As
       a result, it is not clear how you are eligible to use Form S-3 at this
time. Please refer to
       Instruction I.A.3(b) of Form S-3.
2.     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." Please disclose whether this provision applies to actions
arising under the
       Securities Act or Exchange Act. In that regard, we 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
 Charles A. Bacon, III
Limbach Holdings, Inc.
July 17, 2019
Page 2
         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.
        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.

      Please contact Sergio Chinos, Staff Attorney, at (202) 551-7844 or Jay
Ingram, Legal
Branch Chief, at (202) 551-3397 with any other questions.



                                                                Sincerely,
FirstName LastNameCharles A. Bacon, III
                                                                Division of
Corporation Finance
Comapany NameLimbach Holdings, Inc.
                                                                Office of
Manufacturing and
July 17, 2019 Page 2                                            Construction
FirstName LastName