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SEC Company Response from KURA SUSHI USA, INC. (KRUS) (CIK 0001772177) (KRUS) — Jul 29, 2019

KURA SUSHI USA, INC. (KRUS) (CIK 0001772177)
Date: July 29, 2019 · CIK: 0001772177 · Accession: 0001193125-19-205131

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File numbers found in text: 333-232551

Date
July 29, 2019
Author
Zach Dombrowski
Form
CORRESP
Company
KURA SUSHI USA, INC. (KRUS) (CIK 0001772177)

Letter

July 29, 2019

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention:

Anne Nguyen Parker, Assistant Director

J. Nolan McWilliams, Attorney-Advisor

Beverly Singleton, Staff Accountant

Doug Jones, Staff Accountant

Re:

Kura Sushi USA, Inc.

Registration Statement on Form S-1

File No. 333-232551

Acceleration Request

Requested Date:

July 31, 2019

Requested Time:

3:00 p.m. Eastern Time

Ladies and Gentlemen:

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned, as representatives of the underwriters of the offering (the “Offering”) of shares of Common Stock of Kura Sushi USA, Inc. (the “Company”), hereby join in the Company’s request that the effectiveness of the Company’s Registration Statement on Form S-1 (File No. 333-232551) become effective on July 31, 2019 at 3:00 p.m., Washington D.C. time, or as soon thereafter as may be practicable.

Pursuant to Rule 460 under the Act, the undersigned, as representatives of the underwriters, wish to advise you that we have carried out the following distribution of the Company’s preliminary prospectus, dated July 22, 2019:

i. Dates of distribution: July 22, 2019 through the date hereof

ii. Number of prospective underwriters to which the preliminary prospectus was furnished: five

iii. Number of preliminary prospectuses furnished to investors: approximately 600

iv. Number of preliminary prospectuses distributed to others, including the Company, the Company’s counsel, and underwriters’ counsel: approximately 50

The undersigned advise that they have complied and will continue to comply, and that they have been informed by the participating underwriters that they have complied and will continue to comply, with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Remainder of page intentionally left blank]

Very truly yours,
BMO Capital Markets Corp.

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

 July 29, 2019

VIA EDGAR

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549

Attention:

 Anne Nguyen Parker, Assistant Director

J. Nolan McWilliams, Attorney-Advisor

 Beverly Singleton, Staff
Accountant

 Doug Jones, Staff Accountant

Re:

 Kura Sushi USA, Inc.

Registration Statement on Form S-1

File No. 333-232551

 Acceleration Request

 Requested Date:

July 31, 2019

 Requested Time:

3:00 p.m. Eastern Time

 Ladies and Gentlemen:

In accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the
undersigned, as representatives of the underwriters of the offering (the “Offering”) of shares of Common Stock of Kura Sushi USA, Inc. (the “Company”), hereby join in the Company’s request that the effectiveness of the
Company’s Registration Statement on Form S-1 (File No. 333-232551) become effective on July 31, 2019 at 3:00 p.m., Washington D.C. time, or as soon thereafter as may be practicable.

Pursuant to Rule 460 under the Act, the undersigned, as representatives of the underwriters, wish to advise you that we have carried out the
following distribution of the Company’s preliminary prospectus, dated July 22, 2019:

i.
 Dates of distribution: July 22, 2019 through the date hereof

ii.
 Number of prospective underwriters to which the preliminary prospectus was furnished: five

iii.
 Number of preliminary prospectuses furnished to investors: approximately 600

iv.
 Number of preliminary prospectuses distributed to others, including the Company, the Company’s counsel,
and underwriters’ counsel: approximately 50

 The undersigned advise that they have complied and will continue to
comply, and that they have been informed by the participating underwriters that they have complied and will continue to comply, with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

[Remainder of page intentionally left blank]

 Very truly yours,

BMO Capital Markets Corp.

 Stephens Inc.

as Representatives of the several Underwriters

BMO Capital Markets Corp.

By:

/s/ Zach Dombrowski

Name:

Zach Dombrowski

Title:

Vice President

Stephens Inc.

By:

/s/ Sarah Campbell

Name:

Sarah Campbell

Title:

Managing Director