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                             February 1, 2023

       Robert E. Sandlin
       Chief Executive Officer
       Patriot Transportation Holding, Inc.
       200 W. Forsyth Street
       7th Floor
       Jacksonville, FL 32202

                                                        Re: Patriot
Transportation Holding, Inc.
                                                            Schedule 13D filed
by Robert E. Sandlin
                                                            Filed January 18,
2023
                                                            File No. 005-88600

       Dear Robert E. Sandlin:

                                                        We have reviewed the
above-captioned filing, and have the following comment.

               Please respond to this letter by amending the filing or by
providing the requested
       information. If a belief exists that our comment does not apply to your
facts and circumstances or
       that an amendment is inappropriate, please advise us why in a response
letter.

              After reviewing any amendment to the filing and any information
provided in response to
       this comment, we may have additional comments.

       Schedule 13D filed January 18, 2023

       General

   1.                                                   We note the date of the
event reported as requiring the filing of the Schedule 13D was
                                                        November 15, 2021. Rule
13d-1(a) of Regulation 13D-G requires the filing of a
                                                        Schedule 13D within 10
days after the acquisition of more than five percent of a class of
                                                        equity securities
specified in Rule 13d-1(i). Based on the reported November 15,
                                                        2021 event date, the
January 18, 2023 filing was not timely filed. Please advise us why
                                                        the Schedule 13D was
not filed within the required 10 days after the acquisition.
               We remind you that the filing persons are responsible for the
accuracy and adequacy of
       their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
 Robert E. Sandlin
Patriot Transportation Holding, Inc.
February 1, 2023
Page 2

       Please direct any questions to Michael Killoy at (202) 551-7576 or
Nicholas Panos at
(202) 551-3266.



FirstName LastNameRobert E. Sandlin                        Sincerely,
Comapany NamePatriot Transportation Holding, Inc.
                                                           Division of
Corporation Finance
February 1, 2023 Page 2                                    Office of Mergers &
Acquisitions
FirstName LastName