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CORRESP
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    LAURA
    ANTHONY, ESQ.
    WWW.ALCLAW.COM

    CRAIG
    D. LINDER, ESQ.*
    WWW.SECURITIESLAWBLOG.COM

    JOHN
    CACOMANOLIS, ESQ.**

    Associates
                                            and OF COUNSEL:

    CHAD
    FRIEND, ESQ., LLM
    DIRECT
    E-MAIL: LANTHONY@ALCLAW.COM

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

    JESSICA
    HAGGARD, ESQ. ****

    PETER
    P. LINDLEY, ESQ., CPA, MBA

    JOHN
    LOWY, ESQ.*****

    STUART
    REED, ESQ.

    LAZARUS
    ROTHSTEIN, ESQ.

    SVETLANA
    ROVENSKAYA, ESQ.******

    HARRIS
    TULCHIN, ESQ. *******

*licensed
in CA, FL and NY

**licensed
in FL and NY

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

****licensed
in Missouri

*****licensed
in NY and NJ

******licensed
in NY and NJ

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

August
2, 2024

VIA
ELECTRONIC EDGAR FILING

Office
of Trade & Services

Division
of Corporation Finance

Securities
and Exchange Commission

100
F. Street, N.E.

Washington,
D.C. 20549

    Re:
    rYojbaba
                                            Co., Ltd. – CIK No. 0002012600

    Amendment
    No.1 to Draft Registration Statement on Form F-1 (DRS), submitted June 25, 2024

    Registration
    Statement on Form F-1, submitted August 2, 2024

Dear
Sir or Madam:

This
letter responds to the correspondence from the Staff of the Securities and Exchange Commission (the “SEC”) dated July 3,
2024 to Ryoji Baba, the Chief Executive Officer of rYojbaba Co., Ltd. (the “Company”), providing comments on the above-referenced
Amendment No. 1 to Draft Registration Statement on Form, submitted June 25, 2024 by the Company (the “Prior Filing”).

The
Company today filed via EDGAR its non-confidential Registration Statement on Form F-1 (the “New Filing”). We will
separately provide you with a courtesy copy of the New Filing that is redlined against the Prior Filing. The remainder of this letter
responds to the Staff’s comments on the Prior Filing, which are set forth below along with our responses on behalf of the Company.
We trust you shall deem the contents of this transmittal letter responsive to your comment letter.

Amendment
No.1 to Draft Registration Statement on Form F-1, Submitted June 25, 2024

Osteopathic
Industry, page 2

    1.
    Comment:
    We note your response to comment 3 and reissue in part. We acknowledge the new disclosure explaining the nature of the Japanese
    government subsidies; however, please also clarify if the “social problems” the Japanese government subsidy is targeting
    are the same problems as the labor rights your consulting services specialize in.

    Response:
    In response to the Staff’s comment, we have clarified in the New Filing that the social problems the Japanese government
    subsidy is targeting are the same problems as the labor rights our consulting services specialize in.

Note
to Consolidated Financial Statements

Note
6 – Intangible Assets, page F-14

    2.
    Comment:
    For the acquired contracts with 10 customers for HR consulting services from Global HR Technology Co., Ltd. (GHRT), of which your
    CEO is a shareholder, which was executed on September 15, 2023, please explain the rationale for accounting for the acquisition of
    customer contracts as intangible assets, how you determined the fair value of these customer contracts, and your consideration for
    accounting for this transaction as entities under common control. We note in your disclosure on page F-7 the acquisition of Sakai
    from GHRT, which is controlled by your directors, was accounted for as entities under common control. Also, explain and disclose
    who is receiving the consideration paid of $1,726,433, and the relationship of your CEO/majority shareholder and board of directors
    with the ownership and board of GHRT at the time of this transaction. Refer to ASC 805- 50 and ASC 850-10-50.

    Response:
                                            We respectfully advise the Staff that the acquisition of customer contracts is not
                                            classified as a transaction under common control from the following reasoning.

    (a)
    The accounting for this transaction and the relationship of our CEO

    As
    of January 1, 2022, Global HR Technology Co., Ltd. (“GHRT”) was majority-owned by the CEO and director of rYojbaba Co.,
    Ltd., Ryoji Baba (34.35% directly owned by him and 16.04% indirectly owned by him through Great Shine Enterprises Ltd., his asset
    management company, which Mr. Baba owned 100%). However, on December 29, 2022, Mr. Baba sold all his shares in Great Shine Enterprises
    Ltd. to a third party. Therefore, Mr. Baba no longer had a 16.04% ownership in GHRT through Great Shine Enterprise Ltd. As a result,
    Mr. Baba’s remaining ownership interest in GHRT was 34.35% and he no longer had control through his voting interest. Therefore,
    on and after December 29, 2022, GHRT and rYojbaba Co., Ltd. would no longer be considered under common control under ASC810-10-15-8
    and ASC 805-50. Notwithstanding, this transaction should be accounted for as a related party transaction between GHRT and rYojbaba
    Co., Ltd. under ASC850-10-50. To clarify, we revised Notes 1 and 6 of the audited financial statements for the year ended December
    31, 2023 to the Form F-1.

Amendment
No.1 to Draft Registration Statement on Form F-1, Submitted June 25, 2024

Osteopathic
Industry, page 3

    (b)
                                            The rationale for accounting

    GHRT
    provides labor consulting services similar to rYojbaba Co., Ltd. and maintained good relationships with customers of the 10 customer
    contracts. Although the 10 customer contracts lack physical evidence, the acquisition of these customer contracts from GHRT directly
    provides the benefit of increasing revenues to rYojbaba Co., Ltd. The Company determined to treat and classify these customer contracts
    as intangible assets other than goodwill under ASC350-30, based on the consideration that it is more appropriate to treat them as
    intangible assets, not as an expense, as these customer contracts are estimated to provide future economic benefit to the Company.

    In
    accordance with ASC 805-50-30-2, asset acquisition, in which the consideration given is cash, is measured by the amount of cash paid,
    which generally includes the transaction costs of the asset acquisition. In addition, the Company determined to measure the customer
    contracts and related customer relationship at cost based on the guidance, KPMG Handbook Asset Acquisitions.

    (c)
    The fair value determination and the receiver of consideration

    In
    accordance with ASC 350-30, Mr. Baba, the CEO, considered the historical experience in the customer relationships that occurred when
    the customers were customers of GHRT. As the CEO had historical experience on the 10 customer contracts, he determined and negotiated
    with the GHRT management, the recipient of cash consideration, a cash sales price of 269,346,000 yen (US$1,726,433) including consumption
    tax which was paid.

    The
    negotiation estimated an acquisition fair value based on the annual consulting fees multiplied by 7 years since the HR services are
    recurring work. It was estimated that the consulting services are expected to be renewed every year and continue over 7 years.

    In
    terms of the historical service periods, management analyzed contract periods for the 10 contracts based on both the service history
    and market information in the consulting industry in Japan, which is presented in the footnotes of listed consulting companies’
    disclosure regarding customer relationship acquisitions. While the average service period for the 10 contracts was 4.2 years as of
    the succession subject to the history, the period was 12.1 years subject to the market information. Considering these results of
    the analysis, management assessed that value based on the consulting period should be determined from 4 years to 12 years.

    Based
    on the analysis above, the Company concluded that the acquisition price should have been calculated by multiplying the annual consulting
    fee of GHRT by 7 years, which is almost in the middle of the range from 4 years to 12 years.

If
the Staff has any further comments regarding 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,
    LINDER & CACOMANOLIS, PLLC

    By:

    /s/
    Laura Anthony

    Laura
    Anthony, Esq.

    cc:
    Robert
    Shapiro /U.S. Securities and Exchange Commission

    Lyn
    Shenk /U.S. Securities and Exchange Commission

    Nicholas
    Nalbantian /U.S. Securities and Exchange Commission

    Dietrich
    King /U.S. Securities and Exchange Commission

    Ryoji
    Baba / rYojbaba Co., Ltd.

    Craig
    D. Linder, Esq./Anthony, Linder & Cacomanolis, PLLC

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