SecProbe.io

Mail Stop 3233
March 13, 2017

Via E -mail
Wanjun Xie, Chief Executive Officer
Achison Inc.
3906 Main Street
Suite 207
Flushing, NY 11354

Re: Achison, Inc.
Amendment No. 7 to Registration Statement on Form S -1
Filed February 15, 2017
  File No. 333-211051

Dear Mr. Xie:

We have reviewed your amended 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 am ending 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 December 21, 2016 letter.

General

1. We note your response to our prior comments 1, 2 and 11, and your disclosure in the
prospectus summary and in the liquidity section that Lansdale is a holding company. Please
supplementally tell us the entities owned by Lansdale. Also clarify whether Lans dale is your
parent company and if it holds or intends to hold sufficient shares to become your parent
company. In this regard, we note your disclosure in the liquidity section that Lansdale Inc.
will resell some of your shares after two years.

Wanjun Xie, Chief Executive Officer
Achison Inc.
March 13, 2017
Page 2

 Prospe ctus Cover Page

2. We note your disclosure that the offering will end 29 days after the registration statement is
effective. Please tell us the basis for this time frame, including how you intend to sell 99.9
billion shares within 29 days. In this regard, we  remind you of the undertaking in Item
512(a)(3), which requires you to remove from registration by means of a post -effective
amendment any of the securities being registered which remain unsold at the termination of
the offering. Alternatively, refer to R ule 415(a)(2) for guidance in setting the appropriate
time frame.

Prospectus Summary, page 6

3. We note your response to our prior comments 11 and 15.  Please revise paragraph 3 to state
that you will reimburse Blueville, Inc. and clarify the amount owed to  date. Also, revise your
disclosure in the “Other Expenses of Issuance and Distribution” section to indicate, if true,
that the $13,800 will be reimbursed.

Exhibit 5, Legal Opinion

4. We refer to paragraph 6 of the opinion where counsel assumes that the iss uance and delivery
of the Registered Securities will not violate any applicable law, rule or regulation to which
the company is subject. It is inappropriate for counsel to include in its opinion assumptions
that assume any of the material facts underlying the opinion or any readily ascertainable
facts. Please ask counsel to revise the opinion to delete this assumption. Refer to the Division
of Corporation Finance’s Staff Legal Bulletin No. 19 for guidance.

5. We note your response to our prior comment 18. Ass umption (vii) in paragraph 7 continues
to assume that you have a sufficient number of authorized shares as of the date of the
opinion. Please have counsel revise the legal opinion to delete the assumption and to clarify
separately that, as of the date of t he opinion, you have a sufficient number of authorized
shares. Refer to the Division of Corporation Finance’s Staff Legal Bulletin No. 19 for
guidance.

You may contact Paul Cline, Staff Accountant, at (202) 551 -3851 or Wilson Lee, Staff
Accountant, at (2 02) 551 -3468 if you have questions regarding comments on the financial statements
and related matters.  Please contact Stacie Gorman at (202) 551 -3585 or me at (202) 551 -3673 with
any other questions.

Sincerely,

 /s/ Folake Ayoola

Folake Ayoola
Senior  Counsel
        Office of Real Estate and
Commodities