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February 9, 2023
Hiroyuki Sugimoto
Chairman and Chief Executive Officer
SYLA Technologies Co., Ltd.
Ebisu Prime Square Tower 7F, 1-1-39
Hiroo, Shibuya-ku, Tokyo, Japan
Re:SYLA Technologies Co., Ltd.
Amendment No. 4 to Registration Statement on Form F-1
Filed January 31, 2023
File No. 333-268420
Dear Hiroyuki Sugimoto:
            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 amending 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 January 24, 2023 letter.
Amendment No. 4 to Registration Statement on Form F-1 filed January 31, 2023
Business Overview , page 1
1.We note your response to our prior comment 1 stating that you lease the building in which
the data center is located to Getworks.  Please address the following:
•Provide us the details of the significant lease terms with Getworks;
•Tell us if the lease payments you receive vary based on mining outcomes or anything
else related to Getwork's mining business;
•Explain whether your business may earn any income from Getworks outside of fixed
monthly lease payments;
•Tell us whether you have a significant asset concentration leased to a single tenant as
a result of entering into a lease agreement with Getworks and if so, what

 FirstName LastNameHiroyuki Sugimoto
 Comapany NameSYLA Technologies Co., Ltd.
 February 9, 2023 Page 2
 FirstName LastName
Hiroyuki Sugimoto
SYLA Technologies Co., Ltd.
February 9, 2023
Page 2
consideration you gave to filing audited financial statements of Getworks; and
•Tell us the value of the building (and its land, if applicable) recorded on the balance
sheet as of the periods presented.
Index to Financial Statements, page F-1
2.We note your response to our prior comment 3 indicating that the disposition of the
mining business did not meet the asset, investment and income threshold test for
providing pro forma financial statements.  Please provide us with the details of the income
component of your income test calculation, which compares your proportionate share of
consolidated income or loss from continuing operations before taxes of the mining
machine business to your consolidated income from continuing operations before taxes.
We refer you to Rule 1-02(w)(1)(iii) of Regulation S-X.  Additionally, please further
explain to us how you considered net earnings of the disposed mining machine business
in making the determination that the disposal did not represent a strategic shift and did not
meet the criteria for presentation as discontinued operations.
            You may contact Babette Cooper at 202-551-3396 or Isaac Esquivel at 202-551-3395 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Benjamin Holt at 202-551-6614 or Jeffrey Gabor at 202-551-2544 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Craig D. Linder, Esq.