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                              January 20, 2023

       Eiji Nagahara
       President and Chief Executive Officer
       LEAD REAL ESTATE CO., LTD.
       6F, MFPR Shibuya Nanpeidai Building 16-11
       Nampeidai-cho, Shibuya-ku
       Tokyo, 150-0036, Japan

                                                        Re: LEAD REAL ESTATE
CO., LTD.
                                                            Amendment No. 3 to
Registration Statement on Form F-1
                                                            Filed January 4,
2023
                                                            File No. 333-266762

       Dear Eiji Nagahara:

            We have reviewed your amended registration statement and have the
following
       comment.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comment applies 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 registration statement and
the information you
       provide in response to this comment, we may have additional comments.

       Amendment No. 3 to Registration Statement on Form F-1 filed on January
4, 2023

       General

   1.                                                   We note recent
instances of extreme stock price run-ups followed by rapid price declines
                                                        and stock price
volatility seemingly unrelated to company performance following a
                                                        number of recent
initial public offerings, particularly among companies with relatively
                                                        smaller public floats.
Revise to include a separate risk factor addressing the potential for
                                                        rapid and substantial
price volatility and any known factors particular to your offering that
                                                        may add to this risk
and discuss the risks to investors when investing in stock where the
                                                        price is changing
rapidly. Clearly state that such volatility, including any stock run-up,
                                                        may be unrelated to
your actual or expected operating performance and financial
                                                        condition or prospects,
making it difficult for prospective investors to assess the rapidly
                                                        changing value of your
stock.
 Eiji Nagahara
LEAD REAL ESTATE CO., LTD.
January 20, 2023
Page 2

       You may contact Ameen Hamady at 202-551-3891 or Wilson Lee at
202-551-3468 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Ruairi Regan at 202-551-3269 or Jeffrey Gabor at 202-551-2544 with any
other
questions.



                                                       Sincerely,
FirstName LastNameEiji Nagahara
                                                       Division of Corporation
Finance
Comapany NameLEAD REAL ESTATE CO., LTD.
                                                       Office of Real Estate &
Construction
January 20, 2023 Page 2
cc:       Ying Li, Esq.
FirstName LastName