CORRESP for the Correct SEC letter on September 30, 2016 of the Registration Satement on Form S-1 CIK: 0001672572 3906 Main Street, 207 Flushing, NY11354 VIA EDGAR United States Securities and Exchange Commission Attention: Re: Landbay Inc The follow contents are in response to the Correct SEC letter on September 30, 2016 for the Registration Satement on Form S-1/A: Risk Factors, page 5 1. Please revise to provide risk factor disclosure addressing the conflicts of interest with Mr. Xie managing companies that are engaged in the same business. Please see the amended contents of the Risk Factors 2(7) in page 5 of the Form S-1/A on October 5, 2016. Directors, Executive Officers, Promoters and Control Persons, page 18 2. We note your disclosure regarding the multiple filers Mr. Xie is involved with and that "all of these corporations are all engaged in the same business." Please address the inherent conflicts of interest of running companies that are engaged in the same business and how your company will handle the conflicts. Please see the amended contents of the Directors, Executive Officers, Promoters and Control Persons in page 18 of the Form S-1/A on October 5, 2016. 3. We note your disclosure that Mr. Xie is involved with Dewriver Inc. with a principal business of "engaging in the trading of the spot gold and the spot silver." Please revise to clarify the status of the Dewriver company. Please see the amended contents of the Directors, Executive Officers, Promoters and Control Persons in page 18 of the Form S-1/A on October 5, 2016.
Wanjun Xie President |
