December 2, 2024

Fabio Sandri
President and Chief Executive Officer
Pilgrim   s Pride Corporation
1770 Promontory Circle
Greeley, CO 80634-9038

       Re: Pilgrim   s Pride Corporation
           Amendment to Preliminary Proxy Statement
           Filed November 25, 2024
           File No. 001-09273
Dear Fabio Sandri:

       We have reviewed your filing 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
November 6, 2024, letter.

Amendment filed November 25, 2024
General

1.     Please expand your revisions in response to prior comment 4 to clarify
the reasons for
       proposing this amendment. For example, explain what about "the current
financial
       condition of the Company, economic conditions, and other strategic
business and
       financial priorities of the Company" led to proposing this amendment
now?
2.     We note your response to the first element of prior comment 7. However,
it seems any
       tax savings that may result from consolidation benefit your parent by
default, as the
       tax sharing agreement does not appear to have a mechanism to share such
benefits
       with you. Accordingly, please further revise your disclosure to clearly
state that your
       tax liability is not expected to be reduced following consolidation, and
any tax savings
       that may result from consolidation will benefit JBS USA rather than you
or your
       subsidiaries.
 December 2, 2024
Page 2
3.     We reissue the second element of prior comment 7 in part. Please further
revise your
       disclosure to clearly state, as in your Form 10-K, that you have no
present intention to
       pay dividends and to discuss the contractual limitations on the payment
of dividends.
       Further disclose that no payment from JBS USA will be forthcoming unless
your
       dividend policy changes, and assess the likelihood thereof in light of
related
       restrictions.
4.     Disclosure revised in response to the third element of prior comment 7
states that the
       filing of a consolidated return is expected to result in administrative
and cost
       efficiencies, to benefit you, and reduce your tax compliance costs.
Please further
       revise to specifically identify the benefits that you expect to realize.
Additionally
       revise your disclosure to discuss how your administrative and tax
compliance costs
       are expected to be reduced notwithstanding that you will be required to
prepare pro
       forma returns to determine your individual tax liability (for purposes
of making
       payments to JBS USA in such amount) and also assist JBS USA in preparing
       consolidated returns. If the consolidated benefits and reduced costs
will accrue to JBS
       USA rather than to you, then clearly so state.

        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.

      Please contact Jennifer Angelini at 202-551-3047 or Geoffrey Kruczek at
202-551-
3641 with any other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing
cc:   Jeffrey Sherman