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                             August 23, 2022

       Eiji Nagahara
       President and Chief Executive Officer
       LEAD REAL ESTATE CO., LTD.
       6F, MFPR Shibuya Nanpeidai Building 16-11
       Nampeidai-cho, Shibuya-ku
       Tokyo, 150-0036, Japan

                                                        Re: LEAD REAL ESTATE
CO., LTD.
                                                            Registration
Statement on Form F-1
                                                            Filed August 11,
2022
                                                            File No. 333-266762

       Dear Mr. Nagahara:

              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.
Unless we note
       otherwise, our references to prior comments are to comments in our
August 1, 2022 letter.

       Form F-1 filed on August 11, 2022

       Dilution, page 38

   1.                                                   In your discussion
preceding the dilution table, you indicate that as of December 31, 2021,
                                                        your adjusted net
tangible book value would have been $24,612,346, or $1.70 per
                                                        Ordinary Share after
giving effect to the sale of 2,000,000 ADSs and after deduction of
                                                        the estimated
underwriting discounts and offering expenses. However, based on the sum
                                                        of the $22,410,475 net
proceeds disclosed on page 34 and the $1,752,346 net tangible
                                                        book value as of
December 31, 2021 prior to the offering, it appears the adjusted net
                                                        tangible book value as
of December 31, 2021 should be $24,162,821. Therefore, the
                                                        adjusted net tangible
book value per Ordinary Share would be $1.67, which is consistent
 Eiji Nagahara
LEAD REAL ESTATE CO., LTD.
August 23, 2022
Page 2
      with amounts reflected in your dilution calculation disclosed on page 39.
Please clarify
      the discrepancy and/or revise accordingly.
7. Debt, page F-43

2.    We note your response to comment 4 that the actual average payback period
for the short-
      term land borrowings could be up to 12 months and as such the contractual
obligations
      tables on page 53 correctly reflects the contractual maturities of
short-term land
      borrowings due in 2022 and 2023. Given that your contractual obligations
table is as of
      December 31, 2021, it is still not clear why there would be any amounts
in 2023 even with
      the revised maturity period. Please clarify and/or revise accordingly.
3.    You indicate within disclosures on page F-43 that the current portion of
your long term
      debt and short term land borrowings as of December 31, 2021 was 4,352,807
JPY.
      However, the balance sheet on page F-26 reflects a 4,373,154 JPY balance
for the short
      term land borrowings and current portion of long term debt. Please
explain the
      discrepancy and/or revise accordingly.
        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 Ameen Hamady at 202-551-3891 or Wilson Lee at
202-551-3468 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Ruairi Regan at 202-551-3269 or Pam Long at 202-551-3765 with any other
questions.



                                                           Sincerely,
FirstName LastNameEiji Nagahara
                                                           Division of
Corporation Finance
Comapany NameLEAD REAL ESTATE CO., LTD.
                                                           Office of Real
Estate & Construction
August 23, 2022 Page 2
cc:       Ying Li, Esq.
FirstName LastName