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                            January 24, 2024

       Marc Fogassa
       Chief Executive Officer
       Jupiter Gold Corporation
       Rua Vereador Jo  o Alves Praes n   95-A
       Olhos D     gua , MG 39398-000 , Brazil

                                                        Re: Jupiter Gold
Corporation
                                                            Form 20-F for the
Fiscal Year ended December 31, 2022
                                                            Filed April 28,
2023
                                                            File No. 333-214872

       Dear Marc Fogassa:

              We have reviewed your January 12, 2024 response to our comment
letter and have the
       following comments.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our December 13,
       2023 letter.

       Form 20-F for the Fiscal Year ended December 31, 2022

       Information on the Company, page 7

   1.                                                   We understand from your
response to prior comment 1 that you would prefer to limit
                                                        compliance with the
Subpart 1300 disclosure requirements to future filings, beginning
                                                        with your annual report
for the fiscal year ended December 31, 2023, which you intend to
                                                        file by April 29, 2024.
However, you have not provided adequate responses to several
                                                        comments in our prior
letter and have not explained why you believe that an amendment
                                                        should not be filed.
For example, the draft revisions proposed in response to prior
                                                        comment 1 would need to
include the following additional information for each material
                                                        property to comply with
Item 1304(b) of Regulation S-K:

                                                              A description of
infrastructure.
                                                              A description of
the work that you have completed on each property.
 Marc Fogassa
Jupiter Gold Corporation
January 24, 2024
Page 2
                A description of the exploration plan, including timeframe and
cost.
                The total cost or book value of the property at the end of the
period.

         Please further revise your proposed disclosures to address these
requirements, along with
         the concerns outlined in the other comments in this letter, and submit
all of the proposed
         changes in the form of a draft amendment for our review.

         If you believe that an amendment should not be required or would not
be of interest to
         investors, the proposed changes in the form of a draft amendment
should be accompanied
         by an explanation of your rationale, identifying the facts and
circumstances that you
         considered in formulating your view.
2.       We note your response to prior comment 2 stating that you "...will
remove any disclosures
         that are not supportable pursuant to the requirements of Item
1302(a)(1) of Regulation S-
         K," although also indicating that if the information is retained you
would clarify that it
         does not meet these requirements and is publicly available and
consistent with reporting
         standards of the Brazilian national mining agency.

         We continue to believe that you will need to remove estimates of
mineralization from
         your filing that do not meet the resource or reserve definitions in
Item 1300 of Regulation
         S-K, and which you are unable to support in accordance with Item
1302(a)(1) of
         Regulation S-K. We reissue prior comment 2.
3.       We note your response to prior comment 4 stating that the gold bar
illustration in your
         filing "is an example of a product" from your portable alluvial gold
processing plant,
         although you have not provided any details regarding the timeframe or
circumstances of
         its production or how it serves as an appropriate example.

         Unless you are able to show relevant correlation with your properties
or services please
         remove the illustration to avoid misleading inferences.

         However, if you believe that you are able to justify using the
illustration in your filing,
         provide us with the relevant details and a draft of any clarifying
disclosures that you
         propose to accompany the photograph. We reissue prior comment 4.
       Please contact John Coleman at 202-551-3610 or Karl Hiller at
202-551-3686 if you have
questions regarding comments.



FirstName LastNameMarc Fogassa                                  Sincerely,
Comapany NameJupiter Gold Corporation
                                                                Division of
Corporation Finance
January 24, 2024 Page 2                                         Office of
Energy & Transportation
FirstName LastName