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CORRESP
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ANTHONY
L.G., PLLC

    laura
    aNTHONy, esq

    JOHN
    CACOMANOLIS, ESQ*

    CHAD
    FRIEND, ESQ, LLM

    SVETLANA
    ROVENSKAYA, ESQ**

    WWW.ANTHONYPLLC.COM

    WWW.SECURITIESLAWBLOG.COM

    WWW.LAWCAST.COM

    OF
    COUNSEL:

    Jessica
    Haggard, esq. ***

    MICHAEL
    R. GEROE, ESQ, CIPP/US****

    CRAIG
    D. LINDER, ESQ*****

    PETER
    P. LINDLEY, ESQ, CPA, MBA

    john
lowy, esq.******

    STUART
    REED, ESQ

LAZARUS ROTHSTEIN, ESQ.

    Harris
    Tulchin, Esq. *******

    DIRECT
    E-MAIL:

    LANTHONY@ANTHONYPLLC.COM

*licensed
in FL and NY

**licensed
in NY and NJ

***licensed
in Missouri

****licensed
in CA, DC, MO and NY

*****licensed
in CA, FL and NY

******licensed
in NY and NJ

*******licensed
in CA and HI (inactive in HI)

December
15, 2022

VIA
ELECTRONIC EDGAR FILING

Office
of Real Estate and Construction

Division
of Corporation Finance

Securities
and Exchange Commission

100
F. Street, N.E.

Washington,
D.C. 20549

    Re:
    SYLA
    Technologies Co., Ltd.

    Amendment
    No. 1 to Registration Statement on Form F-1

    Filed
    December 6, 2022

    File
    No. 333-268420

Dear
Sir or Madam:

We
have electronically filed herewith on behalf of SYLA Technologies Co., Ltd. (the “Company”) Pre-Effective Amendment
No. 2 (“Amendment No. 2”) to the above-referenced Registration Statement on Form F-1. Amendment No. 2 is marked to
show changes made from the previous filing made on December 6, 2022 (the “Prior Filing”). We have included a narrative
response herein keyed to the comments of the staff of the Division of Corporation Finance (the “Staff”) of the Securities
and Exchange Commission (the “SEC”) set forth in the Staff’s comment letter to Hiroyuki Sugimoto, Chief Executive
Officer of the Company, dated December 14, 2022. We trust you shall deem the contents of this letter responsive to your comment letter.

Amendment
No. 1 to Registration Statement on Form F-1 filed December 6, 2022

Risk
Factors

As
a “foreign private issuer” we are permitted, and intend, to follow certain home country

corporate
governance..., page 21

    1.
    Comment:
    We note your response to comment 3 and reissue the comment. Please revise to ensure that your risk factor disclosure is consistent
    with your disclosure elsewhere. Specifically, please expand your risk factor disclosure to address your plan to follow Japanese law
    with respect to the quorum requirement. Alternatively, you may include a cross reference here to your discussion under Corporate
    Governance Practices on page 113.

    Response:
    We have included a cross reference in the referenced risk factor on page 21 of Amendment No. 2 to the discussion of our home country
    corporate governance practices under Corporate Governance Practices on page 113 of Amendment No. 2.

Description
of Business, page 82

    2.
    Comment:
    We note your response to comment 6 that you “do not engage directly in crypto mining”;

    however,
    it appears you offer services, through both the sale and maintenance of mining machines as well as your AI switch system, that facilitate
    crypto mining. Please revise your disclosure throughout the prospectus to specify your role in this space, including to address recent
    trends and developments. We note, for example, your statements on page 87 regarding the “deterioration of the crypto currency
    market conditions since mid-September 2022” and delays in part deliveries for computer production.

    Response:
    We acknowledge the Staff’s comment. We have revised the disclosure throughout the prospectus in Amendment No. 2 to specify
    our role in the crypto mining space, including addressing recent trends and developments.

Note
2 - Summary of Significant Accounting Policies

(n)
Revenue Recognition, page F-47

    3.
    Comment:
    We note your response to comment 15. Please provide us with further details describing how the mining machine operations and management
    service arrangements operate. In your response, please tell us which party performs mining operations and who is responsible for
    making mining operational decisions, including but not limited to, the type of crypto currency to mine (e.g., bitcoin, ether, or
    other), as well as when to start and stop mining. Also, tell us if your customers mine on an individual basis or if you provide a
    service to coordinate your customers’ mining efforts. Lastly, clarify if you hold any crypto assets on behalf of your customers
    or any other third party.

    Response:
                                            The Company respectfully advises the Staff that in the mining machine operations and
                                            management service arrangement, the Company’s only performance obligation is to provide
                                            an environment for the mining machines to operate continuously throughout the contract period.
                                            The customers of the Company perform mining on an individual basis, by joining different
                                            mining pools, the decision of which is made at the sole discretion of each customer, including
                                            but not limited to the type of crypto currency to mine, the type of mining pool to join,
                                            the time to start or stop mining etc. The Company does not provide any service to coordinate
                                            its customers’ mining efforts. The Company does not hold any crypto asset on behalf
                                            of the customers or any other third party. The Company respectfully advises the Staff that the mining machine operations and management service income represents
0.24% of the total revenues for the six months ended June 30, 2022, as shown in Note 17 – Disaggregation of Revenues to the unaudited
financial statements for the six months ended June 30, 2022 and 2021.

    4.
    Comment:
    We note your response to comment 15. Please explain in greater detail the fee structure for providing mining machine operation
    and management services, including whether it is flat (e.g., flat monthly fee) or variable (e.g., percentage of fees earned for successful
    mining efforts). If fees vary by the service provided, please also clarify the differences in fee structure for each type of service.

    Response:
                                            The Company respectfully advises the Staff that the fee charged to the customers is based
                                            on utilities consumed by mining machines of each customer, mainly including air conditioning,
                                            electricity etc. The fee structure is not designed to be based on the successful mining efforts.
                                            The fees do not vary by the services provided and there is only one fee structure, as the
                                            Company only provides one type of service, which is to provide an environment for the mining
                                            machines to operate continuously throughout the period to its customers.

Exhibits

    5.
    Comment:
    We note Exhibit 23.4 filed in response to comment 5 is not signed and does not explicitly reference the registrant or the filing.
    Please have the Japan Marketing Research Organization provide a signed consent expressly stating that it consents to the use of its
    name and the referenced information in this registration statement. Refer to Rule 436 of Regulation S-K.

    Response:
    We have filed a new Exhibit 23.4 to Amendment No. 2 that is signed by the Japan Marketing Research Organization and explicitly
    references the Company and the filing and states that the Japan Marketing Research Organization consents to the use of its name and
    the referenced information in the registration statement.

If
the Staff has any further comments regarding Pre-Effective Amendment No. 2 to the registration statement on Form F-1, or any subsequent
amendments to the Company’s registration statement on Form F-1, please feel free to contact the undersigned.

    Anthony
    L.G., PLLC

    By:

    /s/
    Laura Anthony

    Laura
    Anthony, Esq.

    cc:
    Babette
    Cooper /U.S. Securities and Exchange Commission

    Isaac
    Esquivel /U.S. Securities and Exchange Commission

    Isabel
    Rivera /U.S. Securities and Exchange Commission

    Maryse
    Mills-Apenteng /U.S. Securities and Exchange Commission

    Hiroyuki
    Sugimoto /SYLA Technologies Co., Ltd

    Craig
    D. Linder, Esq./Anthony L.G., PLLC

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