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United States securities and exchange commission logo





                            July 25, 2023

       Kevin Berryman
       Chief Financial Officer
       JACOBS SOLUTIONS INC.
       1999 Bryan Street Suite 1200
       Dallas, Texas 75201

                                                        Re: JACOBS SOLUTIONS
INC.
                                                            Form 10-K for the
year ended September 30, 2022
                                                            Filed on November
21, 2022
                                                            Form 8-K filed on
February 7, 2023
                                                            File No. 001-07463

       Dear Kevin Berryman:

              We have reviewed your June 23, 2023 response to our comment
letter 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

               After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       June 2, 2023 letter.

       Form 8-K filed on February 7, 2023

       Reconciliation of Income Tax Expense from Continuing Operations to
Adjusted Income Tax
       Expense from Continuing Operations, page 14

   1.                                                   Your response to our
comment number 1 states that you view the non-GAAP tax rate as
                                                        an appropriate and
meaningful supplemental measure that provides investors a complete
                                                        perspective of an
annual tax rate. Please clarify this statement as Adjusted Income Tax
                                                        Expense from Continuing
Operations appears to equal or approximate your statutory tax
                                                        rate, but based on the
disclosure in your Form 10-K for the year ended September 30,
                                                        2022, your effective
tax rate in recent years has differed from the statutory tax rate.
   2.                                                   In response to our
comment number 1, you explain that applying the anticipated annual
 Kevin Berryman
JACOBS SOLUTIONS INC.
July 25, 2023
Page 2
         tax rate to each quarterly period provides investors with important
information that allows
         investors to assess trends in your underlying business performance
when discrete tax
         events may otherwise significantly impact your quarterly performance.
Please clarify this
         statement as it appears that discrete tax events could similarly
impact an annual period.
         Also, as Adjusted Income Tax Expense from Continuing Operations
relates to an interim
         period, tell us how you considered Question 102.11 of the Compliance
and Disclosure
         Interpretations on Non-GAAP Financial Measures which states that
non-GAAP
         performance measures should include current and deferred income tax
expense
         commensurate with the non-GAAP measure of profitability.
      You may contact Ameen Hamady at 202-551-3891 or in his absence at Shannon
Menjivar at 202-551-3856 if you any questions.



FirstName LastNameKevin Berryman                              Sincerely,
Comapany NameJACOBS SOLUTIONS INC.
                                                              Division of
Corporation Finance
July 25, 2023 Page 2                                          Office of Real
Estate & Construction
FirstName LastName
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