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June 4, 2024
Amit Takur
Chief Executive Officer
Robot Consulting Co., Ltd.
Le Graciel Building 2, 6th Floor
5-22-6 Shinbashi, Minato Ward
Tokyo, 105-0005, Japan
Re:Robot Consulting Co., Ltd.
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted May 20, 2024
CIK No. 0002007599
Dear Amit Takur:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Amendment No. 1 to Draft Registration Statement on Form F-1
Prospectus Summary, page 1
1.Disclosure on page 1 states that one of Lawyer Robot's main functions, legal precedent
research, integrates AI. On page 53, you state that it is your strategic decision not to
incorporate AI technology in Lawyer Robot. Please revise to reconcile these apparent
inconsistencies.
Financial Statements - September 30, 2023 and 2022
Note 14. Subsequent Events, page F-16
2.We note that the stock options granted on February 7, 2024 are not exercisable until the
date of listing of your shares on any domestic or foreign financial instruments
exchange. However, since the compensation expense to be recognized at the time of the

 FirstName LastNameAmit Takur
 Comapany NameRobot Consulting Co., Ltd.
 June 4, 2024 Page 2
 FirstName LastName
Amit Takur
Robot Consulting Co., Ltd.
June 4, 2024
Page 2
listing is based on the grant date fair value, i.e. the fair value of the options on February 7,
2024, please disclose the methodology used to determine the fair value of the options on
February 7, 2024 and the amount of unrecognized stock compensation expense as of
February 7, 2024.
Financial Statements - March 31, 2023 and 2022
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page F-23
3.We note that you state there are no performance obligations after the product key is
provided. With a view towards clarifying disclosure, tell us whether or not the customers
have the choice at any time over the software license period to download and run the
product on their own equipment instead of utilizing cloud-based software that you host. If
the customer cannot run the product on their system and is required to utilize your cloud-
based service, it appears that the cloud-based hosting you provide is not a distinct
obligation pursuant to ASC 606-10-25-22 because the customer cannot use the product
without the hosting. Therefore, the hosting should be combined with the software and the
bundle treated as a single performance obligation and revenues should be recognized over
the software license period for the software and hosting performance obligation
bundle. Please revise the accounting policy disclosure here and in the interim financial
statements accordingly.
            Please contact Claire DeLabar at 202-551-3349 or Robert Littlepage at 202-551-3361 if
you have questions regarding comments on the financial statements and related matters. Please
contact Mariam Mansaray at 202-551-6356 or Mitchell Austin at 202-551-3574 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Yung Li