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    LAURA
                                            ANTHONY, ESQ.

    CRAIG
    D. LINDER, ESQ.*

    JOHN
    CACOMANOLIS, ESQ.**

    Associates
    and OF COUNSEL:

    CHAD
    FRIEND, ESQ., LLM

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

    JESSICA
    HAGGARD, ESQ. ****

    christopher
    t. hines *****

    PETER
    P. LINDLEY, ESQ., CPA, MBA

    JOHN
    LOWY, ESQ.******

    STUART
    REED, ESQ.

    LAZARUS
    ROTHSTEIN, ESQ.

    SVETLANA
    ROVENSKAYA, ESQ.*******

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

    WWW.ALCLAW.COM

    WWW.SECURITIESLAWBLOG.COM

    DIRECT
    E-MAIL: LANTHONY@ALCLAW.COM

*licensed
in CA, FL and NY

**licensed
in FL and NY

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

****licensed
in Missouri

*****licensed
in CA and DC

******licensed
in NY and NJ

*******licensed
in NY and NJ

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

November
20, 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.

    Amendment
    No. 2 to Registration Statement on Form F-1

    Filed
    November 8, 2024

    File
    No. 333-281225

Dear
Sir or Madam:

We
have electronically filed herewith on behalf of rYojbaba Co., Ltd. (the “Company”) Pre-Effective Amendment No. 3 (“Amendment
No. 3”) to the above-referenced Registration Statement on Form F-1. Amendment No. 3 is marked to show changes made from the
previous filing made on November 8, 2024 (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 Ryoji Baba, Chief Executive Officer of the Company, dated
November 19, 2024. We trust you shall deem the contents of this letter responsive to your comment letter.

Amendment
No. 2 to Registration Statement on Form F-1, Filed November 8, 2024

Underwriting,
page 127

    1.
    Comment:
    We note that Boustead Securities, LLC is listed as an underwriter in this section, as well as at the bottom of the prospectus
    cover page, but all other reference to them have been removed from the registration statement. In addition, it would appear that
    Boustead Securities, LLC is not listed in Schedule 1 of the included Underwriting Agreement. Please remove all reference to Boustead
    Securities, LLC, or clarify the underwriting relationship between Network 1 Financial Securities Inc., Boustead Securities, LLC and
    you and update the disclosure and underwriting agreement accordingly.

    Response:
    In response to the Staff’s comment, Schedule 1 to the form of Underwriting Agreement (Exhibit 1.1 to Amendment No. 3) has
    been revised to include Boustead Securities, LLC.

Notes
to Unaudited Financial Statements

Note
10 - Shareholders’ Equity

Stock
Acquisition Rights, page F-38

    2.
    Comment:
    Please disclose that the compensation expense related to the 300,000 stock acquisition rights issued to HeartCore on March 3,
    2024 for services as a consultant in connection with a successful proposed initial public offering (IPO) of the company will be recognized
    when the performance condition is met for the award. Refer to ASC 718-10-25-20.

    Response:
    In response to the Staff’s comment, a description regarding the accounting policy on the stock based compensation has been
    added to Note 2 – Summary of Significant Accounting Policy, and the description of the stock acquisition rights in Note 10
    – Shareholders’ Equity has been revised accordingly, in the Notes to Unaudited Financial Statements as of and for the
    six months ended June 30, 2024.

If
the Staff has any further comments regarding Pre-Effective Amendment No. 3 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,
    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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