Correspondence 0001829126-25-007643 from LEIFRAS Co., Ltd. (LFS) (CIK 0002030277)
LEIFRAS Co., Ltd. (LFS) (CIK 0002030277)
Date: Sept. 25, 2025 · CIK: 0002030277 · Accession: 0001829126-25-007643
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File numbers found in text: 333-283712
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CORRESP
1
filename1.htm
Kingswood
Capital Partners LLC
126
E. 56th Street, Suite 22S
New
York, New York 10022
September
25, 2025
VIA
EDGAR
U.S.
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Division of Corporation Finance
Office of Trade & Services
Attention:
Scott
Stringer
Adam
Phippen
Rucha
Pandit
Donald
Field
Re: LEIFRAS
Co., Ltd.
Registration Statement on Form F-1
File No. 333-283712
Ladies
and Gentlemen:
Pursuant
to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), we, as
the representative of the underwriters of the proposed public offering of securities of LEIFRAS Co., Ltd. (the “Company”),
hereby join the Company’s request that the effective date of the above-referenced Registration Statement on Form F-1 be accelerated
so that it will be declared effective at 4:00 p.m., Eastern time, on Monday, September 29, 2025, or at such later time as the Company
or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange
Commission.
Pursuant
to Rule 460 under the Securities Act, we, as the representative of the underwriters, wish to advise you that there will be distributed
to each underwriter or dealer, who is reasonably anticipated to participate in the distribution of the securities, as many copies of
the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution of the preliminary prospectus.
The
undersigned advises that it has complied and will continue to comply, and that it has been informed by the participating underwriters
that they have complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934,
as amended.
Very
truly yours,
Kingswood
Capital Partners LLC
By:
/s/
Tony Tian
Name:
Tony
Tian
Title:
Director