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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)

February
10, 2023

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. 4 to Registration Statement on Form F-1

    Filed
    January 31, 2023

    File
    No. 333-268420

Dear
Sir or Madam:

We
are in receipt of the comment letter, dated February 9, 2023 (“Comment Letter”), of the Securities and Exchange
Commission (the “SEC”) to Hiroyuki Sugimoto, Chief Executive Officer of SYLA Technologies Co., Ltd. (the
“Company”), regarding Amendment No. 4 to the above-referenced Registration Statement on Form F-1. We have
included a narrative response herein keyed to the comments of the staff of the Division of Corporation Finance (the
“Staff”) of the SEC set forth in the Comment Letter. We trust you shall deem the contents of this letter
responsive to the Comment Letter. Please note that the U.S. dollar (“USD”) figures set forth in this letter
have been made at the exchange rate of Japanese yen 135.69 = USD1.00, which was the foreign exchange rate on June 30, 2022 as
reported by the Board of Governors of the Federal Reserve System in its weekly release on July 5, 2022. This is the same exchange
rate as set forth in the latest filed amendment to the Form F-1 (Amendment No. 4).

Amendment
No. 4 to Registration Statement on Form F-1 filed January 31, 2023

Business
Overview, page 1

    1.
    Comment:
    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;

    Response:
    The following are details of the significant lease terms with Getworks:

    ●
    Square
    footage: approximately 800 square feet leased to Getworks.

    ●
    Initial
    term of lease: one year lease from January 23, 2023 through January 22, 2024.

    ●
    Renewals:
    automatically renew year-by-year unless one-month advance notice of Getworks to not renew or six-months advance notice of the Company,
    as the landlord, not to renew.

    ●
    Rent:
    Fixed monthly lease payment of USD7,370 payable per month throughout the lease which is due to be paid on 27th each month. No other
    forms of rent are payable.

    ●
    Utilities:
    all utilities including electricity bill are to be paid by Getworks.

    ●
    Tell
    us if the lease payments you receive vary based on mining outcomes or anything else related to Getwork’s mining business;

    Response:
    The lease payments we receive do not 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;

    Response:
    Our business does not and will not 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 consideration you gave to filing audited financial statements of Getworks; and

    Response:
    We do not have a significant asset concentration leased to a single tenant as a result of entering into a lease agreement with
    Getworks. The value of assets leased to Getworks was USD476,085, representing 0.67% (less than 1%) of Property, Plant and Equipment
    (USD70,493,558) as reported on the balance sheet as of June 30, 2022.

    ●
    Tell
    us the value of the building (and its land, if applicable) recorded on the balance sheet as of the periods presented.

    Response:
    The value of the small building leased to Getworks was USD476,085 as of June 30, 2022. We acquired the building in 2022 when
    we commenced our mining machine maintenance business and, therefore, the building was not recorded on our balance sheet as of December
    31, 2021.

Index
to Financial Statements, page F-1

  2.
  Comment: 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.

  Response:
In accordance with Rule 1-02(w)(1)(iii) of Regulation S-X, the significant subsidiary test is met when 1) the absolute value of the
registrant’s and its other subsidiaries’ equity in the tested subsidiary’s consolidated income or loss from continuing
operations before income taxes (after intercompany eliminations) attributable to the controlling interest exceeds 10 percent of the absolute
value of such income or loss of the registrant and its subsidiaries consolidated for the most recently completed fiscal year; and 2)
the registrant’s and its other subsidiaries’ proportionate share of the tested subsidiary’s consolidated total revenue
from continuing operations (after intercompany eliminations) exceeds 10 percent of such total revenue of the registrant and its subsidiaries
consolidated for the most recent completed fiscal year.

The
Company computed 1) and 2) as follows:

    1)
    For
    the year ended December 31, 2022, which is the most recently completed fiscal year prior to disposal, the Company’s equity
    in the mining machine business’s income from continuing operations before income tax was USD1,509,386. The Company’s
    consolidated income from continuing operations before income taxes (after intercompany eliminations) for the same fiscal year was
    USD8,201,213. As a result, the ratio of the Company’s equity in the mining machine business’s income from continuing
    operations before income taxes to the Company’s consolidated income from continuing operations before income taxes was 18.4%.

    2)
    For
    the year ended December 31, 2022, the Company’s share in the mining machine business’s revenue from continuing operations
    was USD7,317,786. The Company’s consolidated revenue (after intercompany eliminations) for the same fiscal year was USD171,978,963.
    As a result, the ratio of the Company’s proportionate share of mining machine business’s revenue from continuing operations
    to the Company’s consolidated revenue from continuing operations was 4.3%.

Please
also see the computation table as below:

    1)
    Income test – income component

    The
    Company’s equity in mining machine business’s income before income tax

    USD1,509,386

    Consolidated
    income before income taxes

    USD8,201,213

    Significance
    percentage

    18.4%

    2)
    Income test – revenue component

    The
    Company’s share in mining machine business’s revenue

    USD7,317,786

    Consolidated
    revenue

    USD171,978,963

    Significance
    percentage

    4.3%

The
Company acknowledged that the test under 1) above exceeded 10%, however, the test under 2) was less than 10%. Rule 1-02(w)(1)(iii) of
Regulation S-X has both income component and revenue component, and the tested subsidiary will meet the significant test only if both
the net income and revenue component are met. The Company respectfully advises the Staff that the computation above was based on unaudited
financial statements as of December 31, 2022 and for the year then ended as the audit for the year ended December 31, 2022 is not expected
to be finished until the end of April 2023.

With
respect to whether the disposal of mining machine business constituted a strategic shift that has a major effect on its operations and
financial result, the Company considered ASC 205-20 and noted the guidance does not provide any “bright lines” on what qualifies
as a major effect, however, it does include five examples. The Company made assessment as follows:

    a)
    The
    sale of a product line that represent 15% of total revenues

    The
    sale of mining machine business only represented 4.3% total revenues for the year ended December 31, 2022.

    b)
    The
    sale of a geographic area represents 20% of total assets

    The
    Company conducted all its business in Japan, and the sale of mining machine business only represented 0.3% of total asset as of December
    31, 2022.

    c)
    The
    sale of all of one type of a reporting entity’s store formats that historically provided 30% to 40% of the reporting entity’s
    net income and 15% of current period net income

    The
    Company did not generate net income from mining machine business prior to fiscal year 2022 as the Company acquired the business at
    the end of December 2021. As such the mining machine business did not contribute any income to the Company historically. The pretax
    income from mining machine business accounted for 18.4% of the Company’s current period pretax income.

    d)
    The
    sale of an equity method investment that represents 20% of the reporting entity’s total assets

    The
    sale of mining machine business only accounted for 0.3% of total assets as of December 31, 2022.

    e)
    The
    sale of 80% of a product line that accounts for 40% of total revenue, but seller retain 20% of its ownership interest

    The
    sale of mining machine business only represented 4.3% of total revenue for the year ended December 31, 2022. The Company did not
    retain any ownership interest after the sale of mining machine business.

When
forming the conclusion of whether the disposal of mining machine business constitute a strategic shift, the Company carefully analyzed
not only the net earnings of the disposed mining machine business, but also other financial aspects such as revenue, total assets and
operating expenses, as the assessment requires management’s judgement and no single factor is determinative in accordance with
ASC 205-20. Based on the additional analysis as above, and both quantitative and qualitative analysis as provided in the response to
the prior SEC comment No. 3, the Company concluded that the disposal of mining machine business as a cessation of a small revenue stream,
did not represent a strategic shift and did not meet the criteria in ASC 205-20 for presentation as discontinued operations. The Company
respectfully advises the Staff that the computation above was based on unaudited financial statements as of December 31, 2022 and for
the year then ended as the audit for the year ended December 31, 2022 is not expected to be finished until the end of April 2023.

If
the Staff has any further comments regarding Pre-Effective Amendment No. 4 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

    Benjamin
    Holt /U.S. Securities and Exchange Commission

    Jeffrey
    Gabor /U.S. Securities and Exchange Commission

    Hiroyuki
    Sugimoto /SYLA Technologies Co., Ltd

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

625
N. FLAGLER DRIVE, #600 ● WEST PALM BEACH, FLORIDA ● 33401 ● PHONE: 561-514-0936 ● FAX 561-514-0832