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CORRESP
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filename1.htm

Ross
Law Group, pllc

1430
Broadway, Suite 1804

New
York, NY 10018

United
States

+1
212 884 9333

www.RossLawGroup.co

July
20, 2023

Ms.
Charli Gibbs-Tabler

Staff
Attorney

Division
of Corporation Finance

Securities
and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

    Re:
    Robot
    Cache US Inc.

    Post-Qualification
    Amendment No. 5 to the Offering Statement on Form 1-A

    Filed
    June 23, 2023

    File
    No. 024-11954

Dear
Ms. Gibbs-Tabler:

The
undersigned, on behalf of Robot Cache US Inc. (the “Company”), respectfully submits this correspondence to
the staff (the “Staff”) of the Securities and Exchange Commission in response to its letter dated July 10,
2023, relating to the Company’s fifth post-qualification amendment (“Amendment No. 5”) to the
offering statement on Form 1-A filed on June 23, 2023. On behalf of the Company, we are concurrently filing a sixth post-qualification
amendment (“Amendment No. 6”) to the offering statement. Capitalized terms used herein but not defined herein
have the definitions assigned to them in Amendment No. 6.

To
facilitate your review, the undersigned, on the Company’s behalf, has reproduced below the Staff’s comments in bold italics,
followed by the Company’s responses.

Mining
— Earning IRON, page 24

    1.
    We
    note that the ERC-20 token IRON has a fixed value of $.01.

    IRON
    is not an ERC-20 token. In response to the Staff’s comment, the Company has added three statements (to the three already
    in Amendment No. 5) to make it clear that IRON is not an ERC-20 token (or any kind of cryptocurrency).

    Please
    revise to clarify how the value of IRON is determined.

    The
    Company does not represent that IRON has a “value,” but it does have a “price,” which the Company established
    solely for administrative purposes, as discussed on page 25.

    In
    addition, to the extent true, revise throughout to clearly disclose that although Robot Cache credits users with IRON equivalent
    to 85% of the value of their NiceHash earnings, Robot Cache retains 100% of the earned Bitcoin.

    In
    response to the Staff’s comment, in each place in Amendment No. 6 where the Company discloses that 85% of the IRON equivalent
    of the Net Amount is sent to Users, the Company has added a notation that it retains the Net Amount of the actual earned
    bitcoin.

    Finally,
    clarify whether the company can change the IRON payout ratio or value and the impact that could have on users of your platform.

The
Company has no plans to change either the IRON payout ratio or IRON’s price but does have the discretion to do both. The
Company has added disclosure to that effect to pages 24 and 25.

Page 2

July 20, 2023

Proprietary
Digital Rights Management Using the Blockchain, page 24

    2.
    We
    note your disclosure that the “[Digital Rights Management (“DRM”)] methodology and software enable us to accurately
    track and enforce a User’s rights with regard to playing, selling or otherwise controlling access to digital content”
    and that “[t]he blockchain’s ability to track “chain of ownership” also means that we can trace who had the
    rights to a particular copy of the game (e.g., a famous influencer) which we believe has significant potential as a collectible and
    scarcity business model.” Please revise to more clearly discuss how your DRM software operates, including how user rights are
    recorded and transferred (such as whether your DRM software generates NFTs for each game sold to users).

    The
    Company has updated its DRM disclosure on page 24 to address the Staff’s comment regarding how the DRM functions on
    the blockchain. Further, the Company has added disclosure to Amendment No. 6 on page 24 to clarify that the Company’s DRM does
    not generate NFTs, as the Company neither participates in, nor enables, any NFT-generating activities.

    In
    addition, provide a materially complete discussion regarding how the royalty rights are recorded, whether on the blockchain or through
    more traditional contracts. To the extent the rights are based on smart-contracts or other on-blockchain mechanisms, revise to include
    a discussion of the risks, limitations, and difficulties in enforcing the royalty or ownership right.

    Royalty
    rights are separate from DRM and are not recorded on the blockchain. In response to the Staff’s comment, the Company has added
    disclosure on page 23 to clarify that, like its peer companies, it records royalty rights through the more traditional means
    of its own internal proprietary secured databases.

Should
subsequent events after the date of this response materially change the Company’s statements herein, the Company will promptly
notify the Staff and further amend the post-qualification amendment accordingly.

If
the Staff has any questions or comments concerning the foregoing, or if it requires any further information, please contact me at the
number or email above.

    Very
    truly yours,

    ROSS
    LAW GROUP, PLLC

    /s/
    Gary J. Ross

    Gary
    J. Ross

    cc:
    Lee
    Jacobson (via email)