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February 6, 2023
Yishai Cohen
Chief Executive Officer
Landa App 2 LLC
6 W. 18th Street
New York, NY 10011
Re:Landa App 2 LLC
Offering Statement on Form 1-A
Post-Qualification Amendment No. 12
Filed January 25, 2023
File No. 024-11648
Dear Yishai Cohen:
            We have reviewed your amendment 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 amending your offering 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 offering statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No, 12 on Form 1-A POS filed January 25, 2023
General
1.We note the revisions made in response to comment 3 and the revised disclosure on page
64 referencing the free stock program and stating that "[d]etails regarding any such
incentive program will be posted on the Landa Mobile App.". Please provide additional
information regarding the amount of offers of "free" shares that have occurred to date.  In
addition, please confirm, if true, that you are using Regulation A for such offers and sales
and that the issuances count toward the annual maximum under Rule 251(a).  Please
revise the cover page and plan of distribution sections to clearly disclose in greater detail
the specific programs the Manager will use to offer such securities.  We also note the
disclosure that the Manager plans to offer various other promotions and incentives to
investors.  Please clarify how the specific promotions and incentive programs will be
communicated to investors.  Additionally, please clearly disclose that the Manager is

 FirstName LastNameYishai Cohen
 Comapany NameLanda App 2 LLC
 February 6, 2023 Page 2
 FirstName LastNameYishai Cohen
Landa App 2 LLC
February 6, 2023
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acting as an underwriter in connection with distributions of such shares or provide a
detailed legal analysis explaining why you believe it is not an underwriter.
2.Please also clarify (and explain how) the Company and especially the Manager (Landa
Holdings Inc.) intend to structure and operate the above-referenced “free stock” program
so as not to violate the trading restrictions under Rules 101 and102 of Regulation M by
making impermissible bid, purchases, and/or attempts to induce any other person to bid or
purchase of the “covered security” (which may be the same security as the “free stock”)
outside of the Reg M “Distribution” during the relevant restricted period.  Please be
advised that we may have additional comments once we have received your written
responses and reviewed any additional information that is provided.
Plan of Distribution, page 64
3.We note your disclosure that the Manager may offer incentives to potential and/or existing
investors in the form of “free” Shares.  Please quantify for us and in your filing the
amount and value of "free" Shares that have been issued as of the date of the offering
circular by Series and in total.
Overview to Unaudited Pro Forma Condensed Combined Financial Statements, page F-2
4.We note your response to our comment 1 and your revision to your offering circular that
the market rate of interest for the Refinance Notes is expected to be in the range of 7% to
10% per annum.  Please further revise the footnote disclosure to your pro forma financial
information to quantify the range of impact of this potential interest rate increase on
interest expense and net income (loss) for each Series and in total.  Refer to Article 11 of
Regulation S-X.
            We will consider qualifying your offering statement at your request.  If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

 FirstName LastNameYishai Cohen
 Comapany NameLanda App 2 LLC
 February 6, 2023 Page 3
 FirstName LastName
Yishai Cohen
Landa App 2 LLC
February 6, 2023
Page 3

            You may contact Jennifer Monick at 202-551-3295 or Robert Telewicz at 202-551-3438
if you have questions regarding comments on the financial statements and related
matters.  Please contact Pam Howell at 202-551-3357 or James Lopez at 202-551-3536 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Mark Schonberger