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                               November 29, 2022

       James Byrd
       Chief Executive Officer
       Stirling Bridge Group, Inc
       37 N. Orange Ave.
       Suite 500
       Orlando, FL 32801

                                                        Re: Stirling Bridge
Group Inc
                                                            Offering Statement
on Form 1-A
                                                            Filed November 17,
2022
                                                            File No. 024-12064

       Dear James Byrd:

              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.

       Form 1-A filed November 17, 2022

       Cover page

   1.                                                   Please revise the
offering circular cover page to include all the information required by
                                                        Item 1 to Part II of
Form 1-A, including a fixed price or range, a cross reference to the risk
                                                        factors, and all
required legends.
       Index to Exhibits, page 34

   2.                                                   Please file a copy of
the auditor   s consent to the use of its audit report in your amended
                                                        Form 1-A. Refer to Item
17 of the General Instructions to Form 1-A.

              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
 James Byrd
Stirling Bridge Group, Inc
November 29, 2022
Page 2

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 Robert Arzonetti at 202-551-8819 or J. Nolan McWilliams,
Acting
Legal Branch Chief, at 202-551-3217 with any other questions.



FirstName LastNameJames Byrd                               Sincerely,
Comapany NameStirling Bridge Group, Inc
                                                           Division of
Corporation Finance
November 29, 2022 Page 2                                   Office of Finance
FirstName LastName