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                           May 22, 2020

       Tie Li
       Director and Chief Financial Officer
       Leading Ideal Inc.
       8th Floor, Block D, Building 8,
       4th District of Wangjing East Garden,
       Chaoyang District, Beijing 100102
       People's Republic of China

                                                        Re: Leading Ideal Inc.
                                                            Amendment No. 3 to
Draft Registration Statement on Form F-1
                                                            Submitted May 8,
2020
                                                            CIK No. 1791706

       Dear Mr. Li:

             We have reviewed your amended draft registration 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Draft Registration Statement on Form F-1 Submitted on May 8, 2020

       Favorable Government Policies Relating to NEVs in China
       Government Subsidies for NEV Purchasers, page 133

   1.                                                   We note your disclosure
on page 20 that the MSRP of Li ONE is higher than the subsidy
                                                        threshold. Please
expand your disclosure here that the MSRP of Li ONE is higher than the
                                                        subsidy threshold.
 Tie Li
Leading Ideal Inc.
May 22, 2020
Page 2
28. Subsequent Events, page F-129

2.    Please disclose the actual date through which subsequent events were
evaluated, as well as
      whether that date is the date the financial statements were issued or the
date the financial
      statements were available to be issued. Refer to ASC 855-10-50-1.
       You may contact Ernest Greene, Staff Accountant at (202) 551-3733 or
Kevin Stertzel,
Staff Accountant at (202) 551-3723 if you have questions regarding comments on
the financial
statements and related matters. Please contact Sherry Haywood, Staff Attorney
at (202) 551-
3345 or Asia Timmons-Pierce, Special Counsel at (202) 551-3754 with any other
questions.



                                                            Sincerely,
FirstName LastNameTie Li
                                                            Division of
Corporation Finance
Comapany NameLeading Ideal Inc.
                                                            Office of
Manufacturing
May 22, 2020 Page 2
cc:       Z. Julie Gao
FirstName LastName