United States securities and exchange commission logo





                              December 6, 2022

       Yishai Cohen
       Chief Executive Officer
       Landa App LLC
       6 W. 18th Street, 12th Floor
       New York, NY 10011

                                                        Re: Landa App LLC
                                                            Amendment No. 1 to
                                                            Offering Statement
on Form 1-A
                                                            Filed September 15,
2022
                                                            File No. 024-11953

       Dear Yishai Cohen:

             We have reviewed your amended 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 amending your offering statement
and providing the
       requested information. 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 offering statement and the
information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
September 23, 2022 letter.

       Response Letter dated October 6, 2022

       General

   1.                                                   In your disclosure
provided in response to comment 3, we note you do not
                                                        quantify currently
outstanding amounts of the Refinance Notes or the Acquisition Notes,
                                                        although there is
disclosure noting that "each prior offered series has paid down or
                                                        otherwise discharged
all or a portion of the outstanding balance of its Acquisition Note."
                                                        If material, please
provide quantitative disclosure regarding the outstanding amounts
                                                        under each of the
Refinance and Acquisition Notes.
 Yishai Cohen
FirstName
Landa AppLastNameYishai   Cohen
           LLC
Comapany6,
December  NameLanda
             2022      App LLC
December
Page 2    6, 2022 Page 2
FirstName LastName
2.       We note your response to comment 4 indicating that the    free stock
 is being paid for by
         the sponsor. Please provide a detailed description of the mechanics of
the free stock
         program, including whether the sponsor purchases the securities to be
issued and the
         timing and steps involved in distributing the securities. Also advise
us how many shares
         have been issued and the value attributed to them. It appears the
Forms 1-A do not
         address the free stock program. Please revise or advise us why you
believe such
         disclosure is not material.
3.       We note your response to comment 5 and ask that you provide updated
narrative
         disclosure for all of the prior 37 series offered, whether open or
closed, including in an
         updated Master Series Table in Appendix A.
       You may contact Babette Cooper at 202-551-3396 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Isabel Rivera at 202-551-3518 or James Lopez at 202-551-3536 with any
other
questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of Real
Estate & Construction
cc:      Mark Schonberger