SEC Comment Letter 0000000000-23-000663 to LEAD REAL ESTATE CO., LTD (LRE) (CIK 0001888980) (LRE)
LEAD REAL ESTATE CO., LTD (LRE) (CIK 0001888980)
Date: Jan. 20, 2023 · CIK: 0001888980 · Accession: 0000000000-23-000663
AI Filing Summary & Sentiment
File numbers found in text: 333-266762
Letter
United States securities and exchange commission logo January 20, 2023 Eiji Nagahara President and Chief Executive Officer LEAD REAL ESTATE CO., LTD. 6F, MFPR Shibuya Nanpeidai Building 16-11 Nampeidai-cho, Shibuya-ku Tokyo, 150-0036, Japan Re:LEAD REAL ESTATE CO., LTD. Amendment No. 3 to Registration Statement on Form F-1 Filed January 4, 2023 File No. 333-266762 Dear Eiji Nagahara: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comment applies 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 this comment, we may have additional comments. Amendment No. 3 to Registration Statement on Form F-1 filed on January 4, 2023 General 1.We note recent instances of extreme stock price run-ups followed by rapid price declines and stock price volatility seemingly unrelated to company performance following a number of recent initial public offerings, particularly among companies with relatively smaller public floats. Revise to include a separate risk factor addressing the potential for rapid and substantial price volatility and any known factors particular to your offering that may add to this risk and discuss the risks to investors when investing in stock where the price is changing rapidly. Clearly state that such volatility, including any stock run-up, may be unrelated to your actual or expected operating performance and financial condition or prospects, making it difficult for prospective investors to assess the rapidly changing value of your stock.
FirstName LastNameEiji Nagahara Comapany NameLEAD REAL ESTATE CO., LTD. January 20, 2023 Page 2 FirstName LastName Eiji Nagahara LEAD REAL ESTATE CO., LTD. January 20, 2023 Page 2 You may contact Ameen Hamady at 202-551-3891 or Wilson Lee at 202-551-3468 if you have questions regarding comments on the financial statements and related matters. Please contact Ruairi Regan at 202-551-3269 or Jeffrey Gabor at 202-551-2544 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Ying Li, Esq.
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United States securities and exchange commission logo
January 20, 2023
Eiji Nagahara
President and Chief Executive Officer
LEAD REAL ESTATE CO., LTD.
6F, MFPR Shibuya Nanpeidai Building 16-11
Nampeidai-cho, Shibuya-ku
Tokyo, 150-0036, Japan
Re:LEAD REAL ESTATE CO., LTD.
Amendment No. 3 to Registration Statement on Form F-1
Filed January 4, 2023
File No. 333-266762
Dear Eiji Nagahara:
We have reviewed your amended registration statement and have the following
comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our comment applies 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 this comment, we may have additional comments.
Amendment No. 3 to Registration Statement on Form F-1 filed on January 4, 2023
General
1.We note recent instances of extreme stock price run-ups followed by rapid price declines
and stock price volatility seemingly unrelated to company performance following a
number of recent initial public offerings, particularly among companies with relatively
smaller public floats. Revise to include a separate risk factor addressing the potential for
rapid and substantial price volatility and any known factors particular to your offering that
may add to this risk and discuss the risks to investors when investing in stock where the
price is changing rapidly. Clearly state that such volatility, including any stock run-up,
may be unrelated to your actual or expected operating performance and financial
condition or prospects, making it difficult for prospective investors to assess the rapidly
changing value of your stock.
FirstName LastNameEiji Nagahara
Comapany NameLEAD REAL ESTATE CO., LTD.
January 20, 2023 Page 2
FirstName LastName
Eiji Nagahara
LEAD REAL ESTATE CO., LTD.
January 20, 2023
Page 2
You may contact Ameen Hamady at 202-551-3891 or Wilson Lee at 202-551-3468 if you
have questions regarding comments on the financial statements and related matters. Please
contact Ruairi Regan at 202-551-3269 or Jeffrey Gabor at 202-551-2544 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Ying Li, Esq.