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  LOEB & LOEB LLP

                         901 New York Avenue, N.W.

                         Washington, D.C. 20001

                         345 Park Avenue

                         New York, NY 10154

                         Main 202.618.5000

                         Fax 202.217.2554

                         Main 212.407.4000

                         Fax 212.407.4990

December
5, 2025

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

100
F Street, N.E.

Washington,
D.C. 20549

  Attn:
  Patrick Kuhn

  Theresa Brillant

  Eddie Kim

  Mara Ransom

  Re:
  RIKU DINING GROUP Ltd

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

  Filed November 18, 2025

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

  Filed
  October 8, 2025

  File
  No. 333-290212

Dear
Messrs. Brillant, Kim, and Ransom:

On
behalf of our client, RIKU DINING GROUP Ltd (the “Company” or “we”), we hereby provide a
response to the comments issued in a letter dated December 4, 2025 (the “Staff’s Letter”) regarding the Company’s
Amendment No. 2 to Registration Statement on Form F-1 and Amendment No. 1 to Registration Statement on Form F-1. Contemporaneously, we
are filing the Amendment No. 3 to the Registration Statement on Form F-1 via Edgar (the “Amendment No. 3”).

In
order to facilitate the review by the staff (the “Staff”) of the United States Securities and Exchange Commission
(the “Commission”) of the Amendment No. 3, we have responded, on behalf of the Company, to the comments set forth
in the Staff’s Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the Staff’s comments
and correspond to the numbered paragraph in the Staff’s Letter. All capitalized terms used but not defined in this response letter
have the meanings ascribed to such terms in the Amendment No. 3.

Amendment
No. 2 to Registration Statement on Form F-1 filed November 18, 2025

Compensation
of Directors and Executive Officers, page 141

1. We
                                            note your response to prior comment 2. Please further revise to provide the information called
                                            for by Item 6.B of Form 20-F “for the last full financial year.”

Response:
In response to the Staff’s comment, the Company has amended the disclosures on page 141 of the Amendment No. 3 accordingly.

Consolidated
Financial Statements, page F-1

2. Please
                                            provide updated audited financial statements, or file as an exhibit to the filing the representations
                                            as to why such update is not necessary. Refer to Item 8.A.4 of Form 20-F and Instruction
                                            2 to Item 8.A.4.

Response:
The Company respectfully advises the Staff that the Company are relying on the 15-month requirement for our audited financial statements.
In response to the Staff’s comment, the Company has filed the Request for Waiver and Representation under Item 8.A.4 of Form 20-F
as Exhibit 99.15 to the Amendment No. 3.

Item
7. Recent Sales of Unregistered Securities, page II-1

3. Given
                                            your disclosure that “the Company completed a reclassification of its ordinary shares,”
                                            and “issued new shares to its existing shareholders without any change to the percentage
                                            of shares held by each existing shareholder,” please revise to provide the information
                                            called for by Item 701 of Regulation S-K, or advise.

Response:
In response to the Staff’s comment, the Company has amended the discloses on page II-1 accordingly.

Please
call me at 212-407-4209 if you would like additional information with respect to any of the foregoing. Thank you.

  Sincerely,

  /s/ Janeane
  Ferrari, Esq.

  Janeane Ferrari, Esq.

  Partner

cc:
Luk Siu Fung Mark, Vice Chairman and Executive Director of Riku Dining Group Limited