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                              December 9, 2020

       Kouji Eguchi
       Chief Executive Officer
       Medirom Healthcare Technologies Inc.
       2-3-1 Daiba, Minato-ku
       Tokyo 135-0091, Japan

                                                        Re: Medirom Healthcare
Technologies Inc.
                                                            Registration
Statement on Form F-1
                                                            Filed November 20,
2020
                                                            File No. 333-250762

       Dear Mr. Eguchi:

              We have reviewed your 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 amending your registration
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 registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Registration Statement on Form F-1 filed November 20, 2020

       Prospectus Summary
       Recent Developments, page 1

   1.                                                   We note that you have
provided in your Prospectus Summary preliminary financial
                                                        results for the three
and nine months ended September 30, 2020. Please revise your
                                                        registration statement
to provide context for the preliminary revenue and net loss
                                                        estimates, including
qualitative and quantitative disclosure, by providing estimates for
                                                        operating costs,
expenses or other line items that would balance your disclosure. We also
                                                        note your statement
that "actual results may differ materially from these estimated
                                                        preliminary results."
If you choose to disclose preliminary results, you should be able to
                                                        assert that the actual
results are not expected to differ materially from those reflected in
                                                        the preliminary
results; accordingly, please remove or revise this statement. Finally, we
 Kouji Eguchi
FirstName LastNameKouji   EguchiInc.
Medirom Healthcare  Technologies
Comapany9,
December  NameMedirom
             2020        Healthcare Technologies Inc.
December
Page 2    9, 2020 Page 2
FirstName LastName
         note your statement that final financial results for the period ended
September 30, 2020
         may not be included in the registration statement prior to
effectiveness; please confirm
         your understanding that, if the financial statements for this
financial period are or become
         available prior to the effective date of the registration statement,
they must be included in
         the filing.
Business
Digital Preventative Healthcare Segment
MOTHER Tracker   , page 70

2.       We note your disclosure that pursuant to your production and
development agreement
         with Matrix Industries, Inc. you will be required to pay royalties to
Matrix Industries, Inc.
         "based on a percentage of the gross profit received" from the sale of
your MOTHER
         Tracker    fitness devices and that such "royalty percentage decreases
following the sales
         of the first 10,000 units." Please revise your disclosure to include
more information about
         the royalty payments; for example, a narrow range expressed within ten
percentage points
         or a statement that a percentage is in the low single digits, teens,
etc. likely would be
         sufficient.
Exhibits

3.       We note that Section 7.6 of your Form of Deposit Agreement and Section
23 of your
         Specimen American Depositary Receipt of the Registrant each
         contain a waiver of jury trial provision with respect to any suit,
action or proceeding
         against the company and/or the depositary directly or indirectly.
Please revise the waiver
         of jury trial provisions in your exhibits to disclose, as you do in
your filing, that
         the provisions apply to claims made under the U.S. federal securities
laws and that any
         holder or beneficial owner of ADSs will not be deemed to have waived
the company's or
         the depositary's compliance with U.S. federal securities laws or the
rules and regulations
         promulgated thereunder. Also revise your risk factor disclosure on
page 35 to
         clarify whether the provisions apply to purchasers in secondary
transactions.
 Kouji Eguchi
Medirom Healthcare Technologies Inc.
December 9, 2020
Page 3

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Suying Li at (202) 551-3335 or Linda Cvrkel at (202)
551-3813 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Nicholas Lamparski at (202) 551-4695 or Lilyanna Peyser at (202)
551-3222 with any
other questions.



                                                           Sincerely,
FirstName LastNameKouji Eguchi
                                                           Division of
Corporation Finance
Comapany NameMedirom Healthcare Technologies Inc.
                                                           Office of Trade &
Services
December 9, 2020 Page 3
cc:       Barbara A. Jones
FirstName LastName