SecProbe.io

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)

March
15, 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. 5 to Registration Statement on Form F-1

    Filed
    February 23, 2023

    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. 6 to the above-referenced Registration Statement on Form F-1 (“Amendment No. 6 to Form F-1”). Amendment No. 6
to Form F-1 is marked to show changes made from the previous filing made on February 23, 2023 (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 March 13, 2023. We trust you shall deem the contents of this letter responsive to your
comment letter.

Amendment
No. 5 to Registration Statement on Form F-1 filed February 23, 2023

Management’s
Discussion and Analysis

Results
of Operations

Comparison
of results of operations for the six months ended June 30, 2022 and 2021

Net
Income, page 71

    1.
    Comment: We
    note the addition of the Recent Developments section on page 64. Please tell us your consideration for further revising your
    disclosure to discuss the reason for the fluctuation in either Income before income taxes or Net Income, including a discussion
    quantifying the mining business’s contribution, in your comparison of results for the six months ended June 30, 2022 and
    2021.

    Response: In response
    to the Staff’s comment, we have respectfully added discussion of the reason for the fluctuation in net income, including a
    discussion quantifying the mining business’s contribution, in our management’s discussion and analysis for the six months
    ended June 30, 2022 and 2021.

Index
to Financial Statements, page F-1

    2.
    Comment:
     We have reviewed your response to our prior comment 2. We continue to believe that pro forma financial information related
    to the disposition of your mining machine business is required since it would provide disclosure that would be material to investors.
    Please revise to include pro forma financial statements for the appropriate periods, in accordance with Rule 11-01(a)(8) of Regulation
    S-X.

Response:
In response to the Staff’s comment, we have respectfully included the unaudited pro forma financial statements (i) in “Summary
Unaudited Pro Forma Condensed Combined Financial Information”, a section after “Selected Consolidated Financial Information
and Operating Data”, and (ii) in “Unaudited Pro Forma Condensed Combined Financial Information” section, a section
before “Management’s Discussion and Analysis of Financial Condition and Results of Operations”. We included
an unaudited pro forma condensed combined balance sheet as of June 30, 2022 and an unaudited pro forma condensed combined statement of
operations for the six months ended June 30, 2022 in each section. We did not include statement of operations for the six months
ended June 30, 2021 or for the year ended December 31, 2021 as the Company acquired SYLA Brain Co., Ltd. On December 31, 2021 and did
not generate any revenue or net income from mining machine business prior to January 1, 2022.

In
addition, we acknowledged the Staff’s previous comment of discontinued operation and we made further assessment and concluded the
disposition of the mining machine business constituted a strategic shift that had a major effect on the Company’s operations
and financial results. We will include discontinued operation presentation in our financial statements for the year ended December 31,
2022 as the held for sale criteria is met in December 2022.

If
the Staff has any further comments regarding Pre-Effective Amendment No. 6 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
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