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                               February 6, 2023

       Yishai Cohen
       Chief Executive Officer
       Landa App 2 LLC
       6 W. 18th Street
       New York, NY 10011

                                                        Re: Landa App 2 LLC
                                                            Offering Statement
on Form 1-A
                                                            Post-Qualification
Amendment No. 12
                                                            Filed January 25,
2023
                                                            File No. 024-11648

       Dear Yishai Cohen:

              We have reviewed your amendment 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.

       Amendment No, 12 on Form 1-A POS filed January 25, 2023

       General

   1.                                                   We note the revisions
made in response to comment 3 and the revised disclosure on page
                                                        64 referencing the free
stock program and stating that "[d]etails regarding any such
                                                        incentive program will
be posted on the Landa Mobile App.". Please provide additional
                                                        information regarding
the amount of offers of "free" shares that have occurred to date. In
                                                        addition, please
confirm, if true, that you are using Regulation A for such offers and sales
                                                        and that the issuances
count toward the annual maximum under Rule 251(a). Please
                                                        revise the cover page
and plan of distribution sections to clearly disclose in greater detail
                                                        the specific programs
the Manager will use to offer such securities. We also note the
                                                        disclosure that the
Manager plans to offer various other promotions and incentives to
                                                        investors. Please
clarify how the specific promotions and incentive programs will be
                                                        communicated to
investors. Additionally, please clearly disclose that the Manager is
 Yishai Cohen
FirstName
Landa AppLastNameYishai Cohen
          2 LLC
Comapany6,NameLanda
February   2023      App 2 LLC
February
Page 2 6, 2023 Page 2
FirstName LastName
         acting as an underwriter in connection with distributions of such
shares or provide a
         detailed legal analysis explaining why you believe it is not an
underwriter.
2.       Please also clarify (and explain how) the Company and especially the
Manager (Landa
         Holdings Inc.) intend to structure and operate the above-referenced
free stock    program
         so as not to violate the trading restrictions under Rules 101 and102
of Regulation M by
         making impermissible bid, purchases, and/or attempts to induce any
other person to bid or
         purchase of the    covered security    (which may be the same security
as the    free stock   )
         outside of the Reg M    Distribution    during the relevant restricted
period. Please be
         advised that we may have additional comments once we have received
your written
         responses and reviewed any additional information that is provided.
Plan of Distribution, page 64

3.       We note your disclosure that the Manager may offer incentives to
potential and/or existing
         investors in the form of    free    Shares. Please quantify for us and
in your filing the
         amount and value of "free" Shares that have been issued as of the date
of the offering
         circular by Series and in total.
Overview to Unaudited Pro Forma Condensed Combined Financial Statements, page
F-2

4.       We note your response to our comment 1 and your revision to your
offering circular that
         the market rate of interest for the Refinance Notes is expected to be
in the range of 7% to
         10% per annum. Please further revise the footnote disclosure to your
pro forma financial
         information to quantify the range of impact of this potential interest
rate increase on
         interest expense and net income (loss) for each Series and in total.
Refer to Article 11 of
         Regulation S-X.
        We will consider qualifying your offering statement at your request. If
a participant in
your offering is required to clear its compensation arrangements with FINRA,
please have
FINRA advise us that it has no objections to the compensation arrangements
prior to
qualification.

        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.
 Yishai Cohen
Landa App 2 LLC
February 6, 2023
Page 3



        You may contact Jennifer Monick at 202-551-3295 or Robert Telewicz at
202-551-3438
if you have questions regarding comments on the financial statements and
related
matters. Please contact Pam Howell at 202-551-3357 or James Lopez at
202-551-3536 with any
other questions.



                                                        Sincerely,
FirstName LastNameYishai Cohen
                                                        Division of Corporation
Finance
Comapany NameLanda App 2 LLC
                                                        Office of Real Estate &
Construction
February 6, 2023 Page 3
cc:       Mark Schonberger
FirstName LastName