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                              October 6, 2020

       Yishai Cohen
       Chairman, CEO and President
       Landa App LLC
       1 Pennsylvania Plaza, 36th Floor
       New York, NY 10119

                                                        Re: Landa App LLC
                                                            Amendment No. 1 to
Draft Offering Statement on Form 1-A
                                                            Submitted September
2, 2020
                                                            CIK 0001815103

       Dear Mr. Cohen:

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

       Amendment No.1 to Draft Offering Statement on Form 1-A

       General

   1.                                                   We note your response
to comment 1. Please clarify if you intend to provide information
                                                        about the properties on
the Landa Mobile App that will not also be disclosed in the
                                                        offering circular prior
to qualification. For example, we note disclosure on page 60
                                                        directs potential
investors to review information that is available elsewhere, such as on the
                                                        Landa Mobile App, in
addition to the offering circular and any supplements thereto as
                                                        well as your disclosure
regarding additional sales materials on page 61. To the extent
                                                        there will be
information not disclosed in the offering circular, please identify such
                                                        information and provide
us with your analysis as to why it is not material to investors.
   2.                                                   We note that you
discuss the potential secondary trading of your securities through a
                                                        "Secondary Trading
Platform." Please revise to discuss the status of such platform in
 Yishai Cohen
FirstName
Landa AppLastNameYishai Cohen
            LLC
Comapany
October    NameLanda App LLC
        6, 2020
October
Page 2 6, 2020 Page 2
FirstName LastName
         more detail. For example, please clarify if you have identified a
registered broker-dealer
         as referenced on the cover page of your offering circular.
Risk Factors
The COVID-19 pandemic has adversely affected and may further adversely affect
our business,
page 16

3.       We note your response to comment 3. Please identify the properties
that have been
         adversely affected. In addition, with respect to the two tenants who
were granted waivers
         for late fees, please clarify if the waiver only applied to the late
fees associated with a late
         payment and whether the tenants were able to eventually pay rent for
the months affected.
Description of the Properties, page 43

4.       It appears that you are projecting an initial dividend amount. Please
revise your filing to
         include a distribution table for each property.
Financial Statements, page F-1

5.       We note your response to comment 5 that you will include Company-level
audit opinions.
         We further note your response states that you will obtain one audit
opinion covering the
         combined financial statements in total and for each series listed in
the financial
         statements. Please clarify whether you anticipate obtaining an audit
opinion for the
         Company only or an audit opinion for the Company and each series. In
your response,
         please also clarify whether in preparing these reports, your auditor
will assess materiality
         at the Company level and at the separate series level.
6.       We note your response to comment 6 and your revisions to the filing,
please address the
         following with respect to the eight properties acquired in July 2020.

                Please clarify whether or not these properties were managed by
Landa Holdings LLC
              while they were owned by Landa Properties LLC, and if so, please
clarify if the terms
              of the management agreement were the same while owned by Landa
Properties LLC
              and while owned by you.
                Please tell us the leasing, management, and development
activities that the
              management company has performed since the acquisition of these
eight properties
              from the third party sellers.
                Please clarify whether any mortgage debt was assumed by Landa
Properties, LLC, in
              connection with the purchase of the eight properties from third
parties, and
              clarify whether you assumed any mortgage debt when you acquired
these properties
              from Landa Properties, LLC.
                Please tell us what efforts have been made to obtain financial
statements or other
              financial information from the third-party sellers of the eight
properties for the
              periods prior to the acquisition of these properties by Landa
Properties, LLC.
                Please tell us what expenses are included in your pro forma
statements of operations
 Yishai Cohen
Landa App LLC
October 6, 2020
Page 3
           and what expenses are included in your historical statements of
revenues and certain
           operating expenses of the eight properties, and please tell us if
there are any expense
           items that are excluded from your historical statements of revenues
and certain
           operating expenses that will be comparable to future operations.
             Please clarify if you will record the properties at the same basis
that Landa Properties
           LLC recorded them upon acquisition from the third party sellers.
7.    We note your disclosure that you intend to acquire an additional 10
properties from Landa
      Properties LLC prior to qualification of this Offering Circular. Please
provide additional
      details about the intended acquisition of these 10 properties, including,
but not limited to,
      if you determined the acquisition of these 10 properties is probable. In
your response,
      please tell us how you considered if this Offering Circular will or will
not include series
      that hold these 10 properties in your assessment of probability.
       You may contact Eric McPhee at 202-551-3693 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Ronald (Ron) Alper at 202-551-3329 or Erin E. Martin at 202-551-3391
with any other
questions.



                                                             Sincerely,
FirstName LastNameYishai Cohen
                                                             Division of
Corporation Finance
Comapany NameLanda App LLC
                                                             Office of Real
Estate & Construction
October 6, 2020 Page 3
cc:       Lillian Brown
FirstName LastName