Lead Real Estate Co., Ltd American Depositary Shares (LRE)
Filed: 15 Sep 22, 12:00am
Lead Real Estate Co., Ltd
September 15, 2022
Via EDGAR
Division of Corporation Finance
Office of Real Estate & Construction
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C., 20549
| Attention: | Ameen Hamady |
Wilson Lee
Pam Long
Ruairi Regan
| Re: | Lead Real Estate Co., Ltd |
| Amendment No. 1 to Registration Statement on Form F-1 | |
| Filed September 9, 2022 | |
| File No. 333-266762 |
Ladies and Gentlemen:
This letter is in response to the letter dated September 15, 2022, from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) addressed to Lead Real Estate Co., Ltd (the “Company,” “we,” and “our”). For ease of reference, we have recited the Commission’s comments in this response and numbered them accordingly. An amended Registration Statement on Form F-1 (“Amended Registration Statement No. 2”) is being filed to accompany this letter.
Dilution, page 38
| 1. | We note your response to comment 1 and your revised disclosures. It appears your adjusted net tangible book value after the offering as of December 31, 2021 of $22,065,475 does not include the $1,752,346 net tangible book value as of December 31, 2021 prior to the offering. Based on the sum of the $22,065,475 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 $23,817,821. Please clarify and/or revise accordingly. |
In response to the Staff’s comments, we revised our disclosure on page 38 of Amended Registration Statement No. 2 to correct the adjusted net tangible book value as of December 31, 2021.
We appreciate the assistance the Staff has provided with its comments. If you have any questions, please do not hesitate to call our counsel, Ying Li, Esq., of Hunter Taubman Fischer & Li LLC, at (212) 530-2206.
Very truly yours,
| /s/ Eiji Nagahara | |
| Name: Eiji Nagahara | |
| Title: President and Chief Executive Officer |
| cc: | Ying Li, Esq. |
Hunter Taubman Fischer & Li LLC