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April 23, 2024
Ryoji Baba
Chief Executive Officer
rYojbaba Co., Ltd.
4-3-1, Ohashi, Minami-Ku
Fukuoka-Shi, Fukuoka, 815-0033
Japan
Re:rYojbaba Co., Ltd.
Draft Registration Statement on Form F-1
Submitted March 29, 2024
CIK No. 0002012600
Dear Ryoji Baba:
            We have reviewed your draft registration statement and have the following comment(s).
            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.
Draft Registration Statement on Form F-1, Submitted March 29, 2024
Company Overview, page 1
1.Please disclose here the percentage of your revenue that you derive from your consulting
services and the percentage from your health services.
2.Please clarify on page 2 what is meant by the title "Administrative Scrivener."
3.On page 2, in the fifth paragraph, you refer to and describe select "high unit price
consulting contracts." Please balance this disclosure by clarifying whether these contracts
are representative of the type found in your consulting service business and, if they are not
representative, please clarify the significance of these contracts to your overall business.
In addition, please expand upon and clarify here the process through which the
government is subsidizing the payment of consulting fees.

 FirstName LastNameRyoji Baba
 Comapany NamerYojbaba Co., Ltd.
 April 23, 2024 Page 2
 FirstName LastName
Ryoji Baba
rYojbaba Co., Ltd.
April 23, 2024
Page 2
Osteopathic Industry, page 2
4.Please define and provide a brief description of what you mean by osteopathy medicine.
Organizational Structure, page 4
5.Please disclose the identity or ultimate natural person or persons behind the term "The
Other Shareholder." In addition, please clarify the apparent inconsistency between the
organizational chart that identifies a 19.7% shareholder, and the Principal Shareholders
section which identifies Mr. Saito as a 6.4% shareholder but leaves the remaining 13.3%
holding unaccounted for.
Corporate Information, page 6
6.We note your disclosure that you were founded in 2015, but you also disclose on page 3
that you opened your first osteopathic clinic in 1989. Please clarify your disclosure, here
and elsewhere in the registration statement, to better identify when your business began
and the steps that took you from opening you first osteopathic clinic in 1989 to your
combined osteopathic/labor relations business today. Refer to Item 4.A.4 of Form 20-F, as
incorporated by Item 4.a of Form F-1.
Summary of Risk Factors, page 10
7.We note your disclosure here and on page 14 that COVID-19 "could" adversely impact
your operations; however, your disclosure on page 59 suggests that the COVID-19
pandemic did have a material negative impact on your business. Please updated risk
factors characterized as potential if COVID-19 did have a material impact on your
business.
Risk Factors, page 13
8.We note your disclosure on page 86 that your osteopathic business regularly receives
clients between the ages of 0 and 15. Please clarify whether there are any material risks
associated with treating children and revise your disclosure accordingly.
Risks Related to Our Business
We are implementing new growth strategy, priorities..., page 17
9.We note your disclosure at the end of this risk factor identifying expansion into new
geographical markets as part of your long-term growth strategy. Please consider preparing
a standalone risk factor addressing expansion into new geographic markets, as the current
risk factor heading is relatively broad and does not reflect the content of the risk factor.

 FirstName LastNameRyoji Baba
 Comapany NamerYojbaba Co., Ltd.
 April 23, 2024 Page 3
 FirstName LastName
Ryoji Baba
rYojbaba Co., Ltd.
April 23, 2024
Page 3
Use of Proceeds, page 49
10.We note your disclosure in this section that you may use some of the proceeds to expand
your osteopathic business through mergers and acquisitions as well as franchising. We
also note your disclosure elsewhere in the registration statement, such as on page 25, that
you plan on expanding your business outside of Japan in the United States and Southeast
Asia. If you plan on using the proceeds of this offering to expand internationally, please
state as much and if the proceeds may or will be used to finance acquisitions of other
businesses, give a brief description of such businesses and information on the status of the
acquisitions. Refer to Item 3.C..2 and .4 of Form 20-F, as incorporated by Item 4.a of
Form F-1.
Management's Discussion and Analysis Financial Condition and Results of Operations, page 54
11.We note your risk factor disclosure on page 30 indicating that your osteopathic services
business has experienced "inflationary pressures" and that these inflationary pressures are
"weighing" on the retail sector. Please disclose any known trends or uncertainties that
have had or are reasonably likely to have a material impact on your cash flows, liquidity,
capital resources, cash requirements, financial position, or results of operations arising
from, related to, or caused by inflation.
Description of Business
Osteopathic Industry, page 72
12.We note the disclosure elsewhere in the registration statement describing your relationship
with future "prospective" franchisees. It appears that franchising is a future potential
business segment and not one that currently exists. If that is the case, please disclose as
much in this section to clarify.
Employees
Consulting Services, page 84
13.It would appear that Mr. Baba is the only person currently employed in the Consulting
Services portion of your business. If that is the case, please state as much, or disclose the
total number of full-time and part-time employees. Refer to Item 6.D of Form 20-F, as
incorporated by Item 4.a of Form F-1.
General
14.Please supplementally provide us with copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
present to potential investors in reliance on Section 5(d) of the Securities Act, whether or
not they retain copies of the communications.

 FirstName LastNameRyoji Baba
 Comapany NamerYojbaba Co., Ltd.
 April 23, 2024 Page 4
 FirstName LastName
Ryoji Baba
rYojbaba Co., Ltd.
April 23, 2024
Page 4
            Please contact Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 if you
have questions regarding comments on the financial statements and related matters. Please
contact Nicholas Nalbantian at 202-551-7470 or Dietrich King at 202-551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Craig D. Linder