SecProbe.io

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 Antiaging
Quantum Living Inc.

 135-27
38 th Avenue, #388

 Flushing,
NY 11354

 Telephone:
(929) 990-3255

 December
17, 2025

 VIA
EDGAR

 Securities
and Exchange Commission

 Division
of Corporation Finance

 100
F Street N.E.

 Washington,
D.C. 20549

 Re:
Antiaging Quantum Living Inc.

 Registration
Statement on Form S-1 filed on December 12, 2025

 File
No. 333-292108

 Ladies
and Gentlemen:

 Pursuant
to Rule 461 promulgated under the Securities Act of 1933, as amended, Antiaging Quantum Living Inc. hereby respectfully requests acceleration
of the effectiveness of the above-referenced Registration Statement so that such Registration Statement will become effective as of 4:15
p.m. Eastern Time, on Friday, December 19, 2025, or as soon as practicable thereafter.

 Very
 truly yours,

 Antiaging
 Quantum Living Inc.

 By:
 /s/
 Barry Wan

 Barry
 Wan

 Chief
 Executive Officer

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CORRESP

Request Acceleration of the Effective Date of the Registration Statement Form S-1

ACHISON INC
CIK: 0001672571
3906 Main Street, 207

Flushing, NY11354

July 19, 2017

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Mail Stop 3233

100 F Street, N.E.

Washington, DC 20549

Attention:

     Stacie Gorman

     Folake Ayoola

     Paul Cline

     Wison Lee

Re: Achison Inc

    Registration Statement on Form S-1

    Filed May 2, 2016

    File No. 333-211051

We request acceleration of the effective date of the pending registration statement.

Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

The company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for acceleration. We will consider a written request for acceleration of the effective date of the registration statement as confirmation of the fact that those requesting acceleration are aware of their respective responsibilities under the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed public offering of the securities specified in the above registration statement. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.

Wanjun Xie

Wanjun Xie
President

Achison Inc

Date: July 19, 2017

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CORRESP

CORRESP for the SEC letter of the Registration Satement on Form S-1

Achison INC
CIK: 0001672571
3906 Main Street, 207

Flushing, NY11354

July 18, 2017

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate and Commodities

100 F Street, N.E.

Washington, DC 20549

Attention:

     Folake Ayoola

     Stacie Gorman

     Paul Cline

     Wilson Lee

Re: Achison Inc

    Amendment No. 7 to Registration Satement on Form S-1

    Filed May 18, 2017

    File No. 333-211051

General

1. Please confirm that you reasonably expect to offer and sell the registered $99.9 billion shares of common stock in the next two years. Refer to Rule 415(a)(2).

We confirm that we reasonably expect to offer and sell the registered $99.9 billion shares of common stock in the next two years from the initial effective date of the registration.

Wanjun Xie

Wanjun Xie
President

Achison Inc

Date: July 18, 2017

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CORRESP for the SEC letter of the Registration Satement on Form S-1

Achison INC
CIK: 0001672571
3906 Main Street, 207

Flushing, NY11354

June 29, 2017

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate and Commodities

100 F Street, N.E.

Washington, DC 20549

Attention:

     Folake Ayoola

     Stacie Gorman

     Paul Cline

     Wilson Lee

Re: Achison Inc

    Amendment No. 7 to Registration Satement on Form S-1

    Filed May 18, 2017

    File No. 333-211051

General

1. Please confirm that you reasonably expect to offer and sell the registered $99.9 billion shares of common stock in the next two years. Refer to Rule 415(a)(2).

Please see the amended contents on page 1 of Form S-1/A on June 29, 2017.

Please see the removed contents of the Undertakings on pages 29 of Form S-1/A on June 29, 2017.

2. Please revise to update the financial statements through the fiscal quarter ended March 31, 2017 in accordance to Rule 8-08 of Regulation S-X.

Please see the amended contents of the Financial Statement on pages 12 of Form S-1/A on June 29, 2017.

Exhibit 23

3. Please include updated consents from your independent accountants in your next preeffective amendment.   Please be advised that the consents for the inclusion of the reports from your independent accountants in the registration statement prior to effectiveness should not be older than 30 days.

Please see Exhibits 23.1, 23.2 and 23.3 of Form S-1/A on June 29, 2017.

Wanjun Xie

Wanjun Xie
President

Achison Inc

Date: June 29, 2017

Mail Stop 3233
June 2 , 2017

Via E -mail
Wanjun Xie
Chief Executive Officer
Achison Inc.
3906 Main Street , Suite 207
Flushing, NY 11354

Re: Achison, Inc.
Amendment No. 10 to Registration Statement on Form S -1
Filed May 18, 2017
  File No. 333-211051

Dear Mr. Xie:

We have reviewed your amended registration statement  and have the following
comments .  In some of our comments, we may ask you to provide us with information so  we
may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendm ent is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.   Unless  we note
otherwise , our references to prior comments are to comments in our May 15, 2017 letter .

General

1. Please confirm that you reasonably expect to offer and sell the registered $99.9 billion
shares of common stock in the next two years . Refer to Rule 415(a)(2).

2. Please revis e to update the financial statements through the fiscal quarter ended March
31, 2017 in accordance to Rule 8 -08 of Regulation S -X.

Exhibit 23

3. Please include updated consents from your independent accountants in your next pre -
effective amendment.    Please  be advised that the consents for the inclusion of the reports
from your independent accountants in the registration statement prior to effectiveness
should not be older than 30 days.

Wanjun Xie
Achison Inc.
June 2, 2017
Page 2

 You may contact Paul Cline, Staff Accountant, at (202) 551 -3851 or Wilso n Lee, Staff
Accountant, at (202) 551 -3468 if you have questions regarding comments on the financ ial
statements and related matters.  Please contact Stacie Gorman at (202) 551 -3585 or me at (202)
551-3673 with any other questions.

Sincerely,

 /s/ Folake Ayoola

Folake Ayoola
Senior Counsel
        Office of Real Estate and
Commodities

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CORRESP

CORRESP for the SEC letter of the Registration Satement on Form S-1

Achison INC
CIK: 0001672571
3906 Main Street, 207

Flushing, NY11354

May 17, 2017

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate and Commodities

100 F Street, N.E.

Washington, DC 20549

Attention:

     Folake Ayoola

     Stacie Gorman

     Paul Cline

     Wilson Lee

Re: Achison Inc

    Amendment No. 7 to Registration Satement on Form S-1

    Filed April 21, 2017

    File No. 333-211051

General

1. We note your response to our prior comment 1 and continue to note your disclosure that Lansdale Inc. will intend to hold sufficient shares to become the parent of the Corporation. (emphasis added) Please revise your disclosure to clarify whether you have entered into an oral or written agreement or understanding to sell securities to Lansdale in this public offering. If so, please tell us how this complies with Section 5 of the Securities Act. Alternatively, please revise your disclosure to so clarify.

Please see the amended contents of the Prospectus Summary 4 on page 6 of the Form S-1/A on May 17, 2017.

Exhibit 23

2. Please refer to prior comment 5 and revise to include an updated consent for the audit report issued on the financial statements at and for the period ended March 31, 2015.  Be advised that the consents for both audit reports included in the registration statement are required to be current at the time effectiveness is requested.

Please see the amended contents of Exhibits 23.3 of the Form S-1/A on May 17, 2017.

Wanjun Xie

Wanjun Xie
President

Achison Inc

Date: AMay 17, 2017

Mail Stop 3233
May 15, 2017

Via E -mail
Wanjun Xie, Chief Executive Officer
Achison Inc.
3906 Main Street
Suite 207
Flushing, NY 11354

Re: Achison, Inc.
Amendment No. 9 to Registration Statement on Form S-1
Filed April 21, 2017
  File No. 333-211051

Dear Mr. Xie :

We have reviewed your amended registration statement  and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by amen ding your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any a mendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.   Unless we note
otherwise, our references to prior comments are to comments in our April 17, 2017 letter .

General

1. We note your response to our prior comment 1  and continue to note your disclosure that
“Lansdale Inc. will intend  to hold sufficient shares to become the parent of the
Corporation.”  (emphasis added) Please revise your disclosure to clarify whether you have
entered into an oral or written agreement  or understanding to sell securities to Lansdale in
this public offering. If so, p lease tell us how this complies with Sect ion 5 of the Securities
Act. Alternatively, please revise your disclosure to so clarify.

Wanjun Xie, Chief Executive Officer
Achison Inc.
May 15, 2017
Page 2

Exhibit 23

2. Please refer to prior comment 5 and revise to include an updated consent for the audit
report issued on the financial statements at and for the period ended March 31, 2015.   Be
advised that the consents for both audit reports included in the regis tration statement are
required to be current at the time effectiveness is requested.

You may contact Paul Cline, Staff Accountant, at (202) 551 -3851 or Wilson Lee, Staff
Accountant,  at (202) 551 -3468 if you have questions regarding comments on the financ ial
statements and related matters.  Please contact Stacie Gorman  at (202) 551 -3585 or me at (202)
551-3673 with any other questions.

Sincerely,

 /s/ Folake Ayoola

Folake Ayoola
Senior Counsel
        Office of Real Estate and
Commodities

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CORRESP

CORRESP for the SEC letter of the Registration Satement on Form S-1

Achison INC
CIK: 0001672571
3906 Main Street, 207

Flushing, NY11354

April 21, 2017

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate and Commodities

100 F Street, N.E.

Washington, DC 20549

Attention:

     Folake Ayoola

     Stacie Gorman

     Paul Cline

     Wilson Lee

Re: Achison Inc

    Amendment No. 7 to Registration Satement on Form S-1

    Filed March 24, 2017

    File No. 333-211051

General

1. We note your response to our prior comment 1 and your revised disclosure that "Lansdale
Inc will intend to hold sufficient shares to become the parent of the Corporation." We
further note your disclosure on page 6 that "Lansdale Inc is a holding company..." and
"After two yeay... Lansdale Inc will resale (sic) some shares of the Corporation...which
Lansdale Inc will be holding." It appears that an investment decision has been made that
Lansdale will purchase shares from you. Please tell us how this complies with Section 5
of the Securities Act.

We removed: "Lansdale Inc is a holding company..." and "After two years... Lansdale Inc will resale (sic) some shares of the Corporation...which
Lansdale Inc will be holding."

Please see the amended contents of Risk Factors 2 (5) on page 6 of the Form S-1/A on April 21, 2017.

2. We note your disclosure throughout the prospectus that Lansdale is a holding company.
We further note your disclosure on page 6 where you indicate that you are setting up
several companies in the same industry, namely Landbay, Lemont, Linton and Dewriver.
Please revise your disclosure to clarify whether you or Lansdale is the holding company
for these entities.

Please see the amended contents of Risk Factors 2 (10) on page 7 of the Form S-1/A on April 21, 2017.

Prospectus Summary, page 6

3. We note your response to our prior comment 3 and your revised disclosure in paragraph 3
that you will not reimburse Blueville for expenses paid to date. Please reconcile this
disclosure with your disclosure on page 10 where you indicate that you will reimburse
Blueville for auditing and legal fees.

Please see the amended contents of Interests of Named Experts and Counsel 1 and 2 on page 10 of the Form S-1/A on April 21, 2017.

Exhibit 5. Legal Opinion

4. We note your response to our prior comment 4. The introductory language of paragraph 6
of the legal opinion continues to serve as an unacceptable qualification of the opinion in
paragraph 9, especially as it relates to parts (ii), (iii), and (iv) of paragraph 6. Please ask
counsel to revise the introductory language or to delete parts (ii), (iii), and (iv) of
paragraph 6. Refer to the Division of Corporation Finance's Staff Legal Bulletin No. 19
for guidance.

Please see the amended contents of Exhibits 5 of the Form S-1/A on April 21, 2017.

Exhibit 23

5. Please include an updated consent from your independent accountant in the pre-effective
amendment.

Please see the amended contents of Exhibits 23.3 of the Form S-1/A on April 21, 2017.

Wanjun Xie

Wanjun Xie
President

Achison Inc

Date: April 21, 2017

Mail Stop 3233
April 17, 2017

Via E -mail
Wanjun Xie, Chief Executive Officer
Achison Inc.
3906 Main Street
Suite 207
Flushing, NY 11354

Re: Achison, Inc.
Amendment No. 8 to Registration Statement on Form S-1
Filed March 27, 2017
  File No. 333-211051

Dear Mr. Xie :

We have reviewed your amended registration statement  and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.   Unless we note
otherwise, our references to prior comments are to comments in our March 13, 2017 letter .

General

1. We note your response to our prior comment 1 and your revised disclosure that “ Lansdale
Inc will intend to hold sufficient shares to become the parent of the Corporation.” We
further note your disclosure on page 6 that “Lansdale Inc is a holding company…” and
“After two years… Lansdale Inc will resale (sic) some shares of the Corpora tion… which
Lansdale Inc will be holding.” It appears that an investment decision has been made that
Lansdale will purchase  shares from you . Please tell us how this complies with Section 5
of the Securities Act.

Wanjun Xie, Chief Executive Officer
Achison Inc.
April 17, 2017
Page 2

2. We note your disclosure throughout the pro spectus that Lansdale is a holding company.
We further note your disclosure on page 6 where you indicate that you are setting up
several companies in the same industry, namely Landbay, Lemont, Linton and Dewriver.
Please revise your disclosure to clarify w hether you or Lansdale is the holding company
for these entities.

Prospectus Summary, page 6

3. We note your response to our prior comment 3 and your revised disclosure in paragraph 3
that you will not reimburse Blueville for expenses paid to date. Please reconcile this
disclosure with your disclosure on page 10 where you indicate that you will reimburse
Blueville for auditing and legal fees.

Exhibit 5. Legal Opinion

4. We note your response to our prior comment 4. The introductory language of paragraph 6
of the legal opinion continues to serve as an unacceptable qualification of the opinion in
paragraph 9, especially as it relates to parts (ii), (iii), and (iv) of paragraph 6.  Please ask
counsel to revise the introductory language or to delete parts (ii),  (iii), and (iv) of
paragraph 6. Refer to the Division of Corporation Finance’s Staff Legal Bulletin No. 19
for guidance.

Exhibit 23

5. Please include an updated consent from your independent accountant in the pre -effective
amendment.

You may contact Paul Cline, Staff Accountant, at (202) 551 -3851 or Wilson Lee, Staff
Accountant,  at (202) 551 -3468 if you have questions regarding comments on the financial
statements and related matters.  Please contact Stacie Gorman  at (202) 551 -3585 or me at (202)
551-3673 with any other questions.

Sincerely,

 /s/ Folake Ayoola

Folake Ayoola
Senior Counsel
        Office of Real Estate and
Commodities

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CORRESP

Request to Cancel the Acceleration's Requestion of the Effective Date of the Registration Statement Form S-1

Achison INC
CIK: 0001672571
3906 Main Street, 207

Flushing, NY11354

April 5, 2017

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate and Commodities

100 F Street, N.E.

Washington, DC 20549

Attention:

     Folake Ayoola

     Stacie Gorman

     Paul Cline

     Wilson Lee

Please cancel the acceleration's requestion of the effective date of the registration statement form S-1 of Achison Inc.

    Achison Inc

    Registration Satement on Form S-1

    File No. 333-211051

Wanjun Xie

Wanjun Xie
President

Achison Inc

Date: April 5, 2017

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CORRESP

CORRESP for the SEC letter of the Registration Satement on Form S-1

Achison INC
CIK: 0001672571
3906 Main Street, 207

Flushing, NY11354

March 24, 2017

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate and Commodities

100 F Street, N.E.

Washington, DC 20549

Attention:

     Folake Ayoola

     Stacie Gorman

     Paul Cline

     Wilson Lee

Re: Achison Inc

    Amendment No. 7 to Registration Satement on Form S-1

    Filed February 15, 2017

    File No. 333-211051

The follow contents are in response to the SEC letter on March 13, 2017 for the Registration Satement on Form S-1:

General

1. We note your response to our prior comments 1, 2 and 11, and your disclosure in the
prospectus summary and in the liquidity section that Lansdale is a holding company. Please
supplementally tell us the entities owned by Lansdale. Also clarify whether Lansdale is your
parent company and if it holds or intends to hold sufficient shares to become your parent
company. In this regard, we note your disclosure in the liquidity section that Lansdale Inc.
will resell some of your shares after two years.

Please see the amended contents of the Prospectus Summary 4 on page 6 of Form S-1/A on March 24, 2017.

Prospectus Cover Page

2. We note your disclosure that the offering will end 29 days after the registration statement is
effective. Please tell us the basis for this time frame, including how you intend to sell 99.9
billion shares within 29 days. In this regard, we remind you of the undertaking in Item
512(a)(3), which requires you to remove from registration by means of a post-effective
amendment any of the securities being registered which remain unsold at the termination of
the offering. Alternatively, refer to Rule 415(a)(2) for guidance in setting the appropriate
time frame.

Please see the amended contents of the Prospectus Cover Page 8 on page 3 of Form S-1/A on March 24, 2017.

Prospectus Summary, page 6

3. We note your response to our prior comments 11 and 15. Please revise paragraph 3 to state
that you will reimburse Blueville, Inc. and clarify the amount owed to date. Also, revise your
disclosure in the "Other Expenses of Issuance and Distribution" section to indicate, if true,
that the $13,800 will be reimbursed.

Please see the amended contents of the Prospectus Summary 3 on page 6 of Form S-1/A on March 24, 2017.

Exhibit 5, Legal Opinion

4. We refer to paragraph 6 of the opinion where counsel assumes that the issuance and delivery
of the Registered Securities will not violate any applicable law, rule or regulation to which
the company is subject. It is inappropriate for counsel to include in its opinion assumptions
that assume any of the material facts underlying the opinion or any readily ascertainable
facts. Please ask counsel to revise the opinion to delete this assumption. Refer to the Division
of Corporation Finance's Staff Legal Bulletin No. 19 for guidance.

Please see the amended contents of the Exhibit 5, Legal Opinion of Form S-1/A on March 24, 2017.

5. We note your response to our prior comment 18. Assumption (vii) in paragraph 7 continues
to assume that you have a sufficient number of authorized shares as of the date of the
opinion. Please have counsel revise the legal opinion to delete the assumption and to clarify
separately that, as of the date of the opinion, you have a sufficient number of authorized
shares. Refer to the Division of Corporation Finance's Staff Legal Bulletin No. 19 for
guidance.

Please see the amended contents of the Exhibit 5, Legal Opinion of Form S-1/A on March 24, 2017.

Wanjun Xie

Wanjun Xie
President

Achison Inc

Date: March 24, 2017

Mail Stop 3233
March 13, 2017

Via E -mail
Wanjun Xie, Chief Executive Officer
Achison Inc.
3906 Main Street
Suite 207
Flushing, NY 11354

Re: Achison, Inc.
Amendment No. 7 to Registration Statement on Form S -1
Filed February 15, 2017
  File No. 333-211051

Dear Mr. Xie:

We have reviewed your amended registration statement and have the following comments.
In some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by am ending your registration statement and providing the
requested information.   If you do not believe our comments apply to your facts and circumstances or
do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any  amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.   Unless we note
otherwise, our references to prior comments are to comments in our December 21, 2016 letter.

General

1. We note your response to our prior comments 1, 2 and 11, and your disclosure in the
prospectus summary and in the liquidity section that Lansdale is a holding company. Please
supplementally tell us the entities owned by Lansdale. Also clarify whether Lans dale is your
parent company and if it holds or intends to hold sufficient shares to become your parent
company. In this regard, we note your disclosure in the liquidity section that Lansdale Inc.
will resell some of your shares after two years.

Wanjun Xie, Chief Executive Officer
Achison Inc.
March 13, 2017
Page 2

 Prospe ctus Cover Page

2. We note your disclosure that the offering will end 29 days after the registration statement is
effective. Please tell us the basis for this time frame, including how you intend to sell 99.9
billion shares within 29 days. In this regard, we  remind you of the undertaking in Item
512(a)(3), which requires you to remove from registration by means of a post -effective
amendment any of the securities being registered which remain unsold at the termination of
the offering. Alternatively, refer to R ule 415(a)(2) for guidance in setting the appropriate
time frame.

Prospectus Summary, page 6

3. We note your response to our prior comments 11 and 15.  Please revise paragraph 3 to state
that you will reimburse Blueville, Inc. and clarify the amount owed to  date. Also, revise your
disclosure in the “Other Expenses of Issuance and Distribution” section to indicate, if true,
that the $13,800 will be reimbursed.

Exhibit 5, Legal Opinion

4. We refer to paragraph 6 of the opinion where counsel assumes that the iss uance and delivery
of the Registered Securities will not violate any applicable law, rule or regulation to which
the company is subject. It is inappropriate for counsel to include in its opinion assumptions
that assume any of the material facts underlying the opinion or any readily ascertainable
facts. Please ask counsel to revise the opinion to delete this assumption. Refer to the Division
of Corporation Finance’s Staff Legal Bulletin No. 19 for guidance.

5. We note your response to our prior comment 18. Ass umption (vii) in paragraph 7 continues
to assume that you have a sufficient number of authorized shares as of the date of the
opinion. Please have counsel revise the legal opinion to delete the assumption and to clarify
separately that, as of the date of t he opinion, you have a sufficient number of authorized
shares. Refer to the Division of Corporation Finance’s Staff Legal Bulletin No. 19 for
guidance.

You may contact Paul Cline, Staff Accountant, at (202) 551 -3851 or Wilson Lee, Staff
Accountant, at (2 02) 551 -3468 if you have questions regarding comments on the financial statements
and related matters.  Please contact Stacie Gorman at (202) 551 -3585 or me at (202) 551 -3673 with
any other questions.

Sincerely,

 /s/ Folake Ayoola

Folake Ayoola
Senior  Counsel
        Office of Real Estate and
Commodities

CORRESP
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CORRESP

CORRESP for the SEC letter of the Registration Satement on Form S-1

Achison INC
CIK: 0001672571
3906 Main Street, 207

Flushing, NY11354

February 10, 2017

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate and Commodities

100 F Street, N.E.

Washington, DC 20549

Attention:

     Folake Ayoola

     Stacie Gorman

     Paul Cline

     Wilson Lee

Re: Achison Inc

    Amendment No. 3 to Registration Satement on Form S-1

    Filed November 26, 2016

    File No. 333-211051

The follow contents are in response to the SEC letter on December 21, 2016 for the Registration Satement on Form S-1:

General

1. We note your disclosure in the "certain relationships and related transactions" section that
"[a]fter the registering in SEC will be effective, Lansdale Inc. will purchase
96,000,000,000 Class A common shares of Achison Inc., it will be about 96% shares of
Achison Inc. Lansdale Inc. will pay the purchase by cash." We further note your
disclosure throughout the document were you refer to your parent company. It appears
that an investment decision has been made about the 96 billion shares Lansdale will
purchase. Please tell us how this complies with Section 5 of the Securities Act.
Alternatively, please revise the registration statement to register the 3.9 billion shares that
have not already been sold in a private offering.

We removed "after the registering in SEC will be effective, Lansdale Inc. will purchase
96,000,000,000 Class A common shares of Achison Inc., it will be about 96% shares of
Achison Inc. Lansdale Inc. will pay the purchase by cash."

Please see the amended contents of Certain Relationships and Related Transactions on page 28 of Form S-1/A which was filed on February 20, 2017.

2. We refer to your certificate of incorporation filed as Exhibit 3. Please tell us whether any
shares were issued when you incorporated the company.

There aren't any shares to be issued when we incorporated Achison Inc.

Please see the amended contents of the Cover Pages 3 on page 3 of Form S-1/A which was filed on February 20, 2017.

3. We note your response to our prior comment 1. Please revise your disclosure to
specifically state that you are electing not to be an emerging growth company and will
not utilize the exemptions and accommodations available to emerging growth companies.
Alternatively, please disclose that you are an emerging growth company and revise your
registration statement to:

(1). Describe how and when a company may lose emerging growth company status;

(2). Briefly describe the various exemptions that are available to you, such as
exemptions from Section 404(b) of the Sarbanes-Oxley Act of 2002 and Section
14A(a) and (b) of the Securities Exchange Act of 1934; and
State your election under Section 107(b) of the JOBS Act:
o If you have elected to opt out of the extended transition period for
complying with new or revised accounting standards pursuant to Section
107(b), include a statement that the election is irrevocable; or
o If you have elected to use the extended transition period for complying
with new or revised accounting standards under Section 102(b)(2), provide
a risk factor explaining that this election allows you to delay the adoption
of new or revised accounting standards that have different effective dates
for public and private companies until those standards apply to private
companies. Please state in your risk factor that, as a result of this election,
your financial statements may not be comparable to companies that
comply with public company effective dates. Include a similar statement
in your critical accounting policy disclosures.

Please see the amended contents of the Cover Page on page 3 of Form S-1/A which was filed on February 10, 2017.

4. Please revise your disclosure in the risk factor or plan of distribution section to disclose
the implications of your status as a shell company. For example, please refer to Rule 144
of the Securities Act.

Please see the amended contents of the Plan of Distribution on page 9 of Form S-1/A which was filed on February 10, 2017.

Cover Page of Registration Statement

5. We note your response to our prior comment 4. Please indicate by check mark that the
securities being registered are to be offered on a continuous basis Rule 415.

Please see the amended contents of the Cover Page of Registration Statement on page 1 of Form S-1/A which was filed on February 10, 2017.

Prospectus Cover Page

6. We note your response to our prior comment 6 and your revised disclosure on page 7 that
you have not made any escrow arrangements. Please revise your disclosure in this
section accordingly. Additionally, please revise to provide the date the offering will end.
Please refer to Item 501(b)(8)(iii) of Regulation S-K.

Please see the amended contents of the Prospectus Cover Page 8 on page 3 of Form S-1/A which was filed on February 10, 2017.

Outside Back Cover Page, page 4

7. Please revise your dealer prospectus delivery obligation to state that the obligation
extends for 90 days after the effective date of your registration statement or advise.
Please refer to Section 4(a)(3) of the Securities Act of 1933 and Rule 174 of Regulation
C.

Please see the amended contents of the Outside Back Cover Page on page 4 of Form S-1/A which was filed on February 10, 2017.

Prospectus Summary, page 6

8. We note your disclosure that you are setting "up several companies in same industry" and
you "will split all [your] capital into several portions, and put each portion capital into
each [of your] companies, then each [of your] companies will have a smaller capit..."
Please tell us whether you intend to aggregate each entity's funds into one parent
company rather than maintaining the assets in the individual entities. If so, please revise
your risk factor section to provide related material risks.

Please see the amended contents of the Prospectus Summary on page 6 of Form S-1/A which was filed on February 10, 2017.

9. We note your disclosure that you plan to engage in trading spot gold and silver in
Singapore's markets. Please revise your disclosure, where applicable, to describe the
regulatory environment in Singapore for trading in spot gold and silver. Also include
related risk factors.

Please see the amended contents of the Prospectus Summary 11 on page 6 of Form S-1/A which was filed on February 10, 2017.

Please see the amended contents of the Risk factors 1(3) on page 6 of Form S-1/A which was filed on February 10, 2017.

Plan of Distribution, page 9

10. We note your response to our prior comment 15. Please revise your disclosure to clarify
how Mr. Xie complies with the requirements of Rule 3a4-1(4) of the Exchange Act.

Please see the amended contents of the Plan of Distribution 7 on page 9 of Form S-1/A which was filed on February 10, 2017.

Interest of Named Experts, page 10

11. We note your disclosure that Blueville Inc. will pay the company's auditing and legal
service fees under a managing company agreement. Please revise to clarify, if true, that
these expenses are to be reimbursed to Blueville Inc. by the company under the February
16, 2016 managing company agreement with Blueville Inc. referenced in Note 7 to the
company's unaudited financial statements for the period ended September 30, 2016.

Please see the amended contents of the Interest of Named Experts 1 and 2 on page 10 of Form S-1/A which was filed on February 10, 2017.

Financial Statements, beginning on page 12

Audited Financial Statements for the Periods Ended March 31, 2016 and 2015

12. Noting that the company is a shell company with no significant operations or assets,
please clarify your auditor's consideration of AU Section 341 of the PCAOB Interim
Auditing Standards in determining that no going concern exists.

Please see the amended contents of the Audited Financial Statements for the Periods Ended March 31, 2016 and 2015 on page 15 and page 20 of Form S-1/A which was filed on February 10, 2017.

Please see the amended contents of the Exhibits 7.1 and 7.2 of Form S-1/A which was filed on February 10, 2017.

Liquidity and Capital Resources, pages 22 - 23

13. Reference is made to the promissory letter discussed within Note 6 on page 13. Given
your current status as a shell company, please revise to expand your disclosures to
discuss whether this promissory letter is legally binding. To the extent limitations exist,
please describe such facts and circumstances. Your response and expanded disclosures
should also include relevant background information related to Landsdale, Inc. sufficient
to substantiate its ability to perform on such commitments. Your revised disclosures
should highlight and discuss all plans that management has to alleviate any potential cash
flow concerns.

Please see the amended contents of the Liquidity and Capital Resources on page 22 of Form S-1/A which was filed on February 10, 2017.

Changes in Internal Controls over Financial Reporting and Statement, page 25

14. We note your disclosure that one of the reasons for dismissal of your former independent
accountant was his "limited experience of auditing an Investment Company." Please
revise to explain the reference to "Investment Company," including why experience in
auditing an Investment Company is relevant to your business and whether you are, or
have plans to become, an Investment Company.

Please see the amended contents of the Changes in Internal Controls over Financial Reporting and Statement 1(iii) on page 25 of Form S-1/A which was filed on February 10, 2017.

Please see the amended contents of the Exhibits 16.1 of Form S-1/A which was filed on February 10, 2017.

Part II - Information Not Required in Prospectus, page 23

Other Expenses of Issuance and Distributions, page 28

15. We note your disclosure that Blueville Inc. will pay all offering expenses. Please revise the
table to quantify the offering expenses. Refer to Item 511 of Regulation S-K.

Please see the amended contents of the Other Expenses of Issuance and Distributions on page 29 of Form S-1/A which was filed on February 10, 2017.

Undertakings, page 28

16. Please include the undertakings required by Item 512(a)(1) and (a)(3) of Regulation S-K.

Please see the amended contents of the Undertaking on page 29 of Form S-1/A which was filed on February 10, 2017.

Exhibits and Financial Statement Schedules, page 28

Exhibit 23

17. Please include an updated consent from your independent accountant in the pre-effective
amendment.

Please see the Exhibits 23.1 and 23.2 of Form S-1/A which was filed on February 10, 2017.

Exhibit 5 Filed with Amendment 4 to Form S-1 on November 15, 2016

18. We note your response to our prior comment 24. We note that assumption (vii) in
paragraph 7 now assumes that you have a sufficient number of authorized shares as of the
date of the opinion. Please have counsel revise the legal opinion to clarify that, as of the
date of the opinion, you have a sufficient number of authorized shares.

Please see the amended contents of the Exhibits 5 of Form S-1/A which was filed on February 10, 2017.

Wanjun Xie

Wanjun Xie
President

Achison Inc

Date: February 10, 2017

Mail Stop 3233
December 21 , 2016

Via E -mail
Wanjun Xie, Chief Executive Officer
Achison Inc.
3906 Main Street
Suite 207
Flushing, NY 11354

Re: Achison, Inc.
Amendment No. 6 to Registration Statement on Form S-1
Filed November 26, 2016
  File No. 333-211051

Dear Mr. Xie :

We have reviewed your amended registration statement  and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have additional comments.   Unless we note
otherwise, our references to prior comments are to comments in our October 19, 2016 letter .

General

1. We note your disclosure  in the “certain relationships and related transaction s” section that
“[a]fter the registering in SEC will be effective, Lansdale Inc . will purchase
96,000,000,000 Class A common shares of Achison Inc ., it will be about 96% shares of
Achison Inc. Lansdale Inc . will pay the purchase by cash.”  We further note y our
disclosure throughout the document were you refer to your parent company. It appears
that an investment decision has been made about the 96 billion shares Lansdale will
purchase.  Please tell us how this complies with Section 5 of the Securities Act.

Wanjun Xie, Chief Executive Officer
Achison Inc.
December 21, 2016
Page 2

 Alternatively, please  revise the registration statement to register the 3.9 billion shares that
have not already been sold in a private offering.

2. We refer to your certificate of incorporation filed as Exhibit 3.  Please tell us whether any
shares were iss ued when you incorporated the company.

3. We note your response to our prior comment 1.  Please revise your disclosure to
specifically state that you are electing not to be an emerging growth company and will
not utilize the exemptions and accommodations ava ilable to emerging growth companies.
Alternatively, please disclose that you are an emerging growth company and revise your
registration statement to:

 Describe how and when a company may lose emerging growth company status;

 Briefly describe the various exemptions that are available to you, such as
exemptions from Section 404(b) of the Sarbanes -Oxley Act of 2002 and Section
14A(a) and (b) of the Securities Exchange Act of 1934; and

 State your election under Section 107(b) of the JOBS Act:

o If you have el ected to opt out of the extended transition period for
complying with new or revised accounting standards pursuant to Section
107(b), include a statement that the election is irrevocable; or

o If you have elected to use the extended transition period for co mplying
with new or revised accounting standards under Section 102(b)(2), provide
a risk factor explaining that this election allows you to delay the adoption
of new or revised accounting standards that have different effective dates
for public and private  companies until those standards apply to private
companies.  Please state in your risk factor that, as a result of this election,
your financial statements may not be comparable to companies that
comply with public company effective dates.  Include a simi lar statement
in your critical accounting policy disclosures.

4. Please revise your disclosure  in the risk factor or plan of distribution section to disclose
the implications  of your status as a  shell company. For example, please refer to Rule 144
of the Securities Act.

Cover Page of Registration Statement

5. We note your response to our prior comment 4.  Please indicate by check mark that the
securities being registered are to be offered on a continuous basis Rule 415.

Wanjun Xie, Chief Executive Officer
Achison Inc.
December 21, 2016
Page 3

 Prospectus Cover Page

6. We note your response to our prior comment 6 and your revised disclosure on page 7 that
you have not made any escrow arrangements.  Please revise your disclosure in this
section accordingly. Additionally, please revise to provide the date the offering will  end.
Please refer to Item 501(b)(8)(iii) of Regulation S -K.

Outside Back Cover Page, page 4

7. Please revise your dealer prospectus delivery obligation to state that the obligation
extends for 90 days after the effective date of your registration statemen t or advise.
Please refer to Section 4(a)(3) of the Securities Act of 1933 and Rule 174 of Regulation
C.

Prospectus Summary, page 6

8. We note your disclosure that you are setting “up several companies in same industry” and
you “will split all [your] capit al into several portions, and put each portion capital into
each [of your] companies, then each [of your] companies will have a smaller capital…”
Please tell us whether  you intend to aggregate each entit y’s funds into one parent
company rather than maintai ning the assets in the individual entities.   If so, please revise
your risk factor section to provide  related material risks.

9. We note your disclosure that  you plan to engage in trading  spot gold and silver in
Singapore’s markets. Please revise your disclosure, where applicable, to describe the
regulatory environment in Singapore for trading in spot gold and silver. Also include
related risk factors.

Plan of Distribution, page 9

10. We not e your response to our prior comment 15.  Please revise your disclosure to clarify
how Mr. Xie complies with the requirements of Rule 3a4 -1(4) of the Exchange Act.

Interest of Named Experts, page 10

11. We note your disclosure that Blueville Inc. will pay t he company’s auditing and legal
service fees under a managing company agreement.  Please revise to clarify, if true, that
these expenses are to be reimbursed to Blueville Inc. by the company under the February
16, 2016 managing company agreement with Bluev ille Inc. referenced in Note 7 to the
company’s unaudited financial statements for the period ended September 30, 2016.

Wanjun Xie, Chief Executive Officer
Achison Inc.
December 21, 2016
Page 4

 Financial Statements, beginning on page 12

Audited Financial Statements for the Periods Ended March 31, 2016 and 2015

12. Noting that the company is a shell company with no significant operations or assets,
please clarify your auditor’s consideration of AU Section 341 of the PCAOB Interim
Auditing Standards in determining that no going concern exists.

Liquidity and Capital Resource s, pages 22 - 23

13. Reference is made to the promissory letter discus sed within Note 6 on page 13.  Given
your current status as a shell company, please revise to expand your disclosures to
discuss whether this promissory letter is le gally binding.  To the e xtent limitations exist,
please describe such facts and circumstances.  Your response and expanded disclosures
should also include relevant background information related to Landsdale, Inc. sufficient
to substantiate its ability to  perform on such commitme nts.  Your revised disclosures
should highlight and discuss all plans that management has to alleviate any potential cash
flow concerns.

Changes in Internal Controls over Financial Reporting and Statement, page 25

14. We note your disclosure that one of the reasons for dismissal of your former independent
accountant was his “limited experience of auditing an Investment Company.”   Please
revise  to explain the reference to “Investment Company,” including why experience in
auditing an Investment Company is relev ant to your business and whether you are, or
have plans to become, an Investment Company.

Part II – Information Not Required in Prospectus, page 23

Other Expenses of  Issuance and Distributions, page 28

15. We note your disclosure that Blueville Inc. will  pay all offering expenses. Please revise the
table to quantify the offering expenses.  Refer to Item 511 of Regulation S -K.

Undertakings, page 28

16. Please include the undertakings required by Item 512(a)(1) and (a)(3) of Regulation S -K.

Exhibits and Financ ial Statement Schedules, page 28

Exhibit 2 8

17. Please include an updated consent from your independent accountant in the pre -effective
amendment.

Wanjun Xie, Chief Executive Officer
Achison Inc.
December 21, 2016
Page 5

 Exhibit 5 Filed with Amendment 4 to Form S -1 on November 15, 2016

18. We note your response to our prior comment 24. We note that assumption (vii) in
paragraph 7 now assumes that you have a sufficient number of authorized shares as of the
date of the opinion.  Please have counsel revise the legal opinion to clarify that, as of the
date of the opinion, you hav e a sufficient number of authorized shares.

You may contact Paul Cline at (202)551 -3851 or Wilson Lee  at (202)551 -3468 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Stacie Gorman  at (202)551 -3585 or me at (202)551 -3673 with any other questions.

Sincerely,

 /s/ Folake Ayoola

Folake Ayoola
Senior Counsel
        Office of Real Estate and
Commodities

CORRESP
1
filename1.htm

CORRESP

CORRESP for the SEC letter of the Registration Satement on Form S-1

Achison INC
CIK: 0001672571
3906 Main Street, 207

Flushing, NY11354

November 13, 2016

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate and Commodities

100 F Street, N.E.

Washington, DC 20549

Attention:

     Folake Ayoola

     Stacie Gorman

     Paul Cline

     Wilson Lee

Re: Achison Inc

    Amendment No. 3 to Registration Satement on Form S-1

    Filed September 22, 2016

    File No. 333-211051

The follow contents are in response to the SEC letter on October 19, 2016 for the Registration Satement on Form S-1:

General

1. We note your response to our prior comment 2 and your revised disclosure that you are "an emerging growth company" as defined in the Jumpstart Our Business Startups Act. Please revise your registration statement to:

Describe how and when a company may lose emerging growth company status;

Briefly describe the various exemptions that are available to you, such as exemptions from Section 404(b) of the Sarbanes-Oxley Act of 2002 and Section 14A(a) and (b) of the Securities Exchange Act of 1934; and

State your election under Section 107(b) of the JOBS Act:

If you have elected to opt out of the extended transition period for complying with new or revised accounting standards pursuant to Section 107(b), include a statement that the election is irrevocable; or

If you have elected to use the extended transition period for complying with new or revised accounting standards under Section 102(b)(2), provide a risk factor explaining that this election allows you to delay the adoption of new or revised accounting standards that have different effective dates for public and private companies until those standards apply to private companies. Please state in your risk factor that, as a result of this election, your financial statements may not be comparable to companies that comply with public company effective dates. Include a similar statement in your critical accounting policy disclosures.

The Corporation doesn.t need an emerging growth company status, so the Corporation decide to give up its emerging growth company status. We remove that "The Corporation is an emerging growth company."

2. We note your response to our prior comment 4 where you state that you do not "have any [plans] for merger and acquisition in the future." In the forepart of the prospectus, please include an affirmative statement to make clear that the company has no present plans to be acquired or to merge with another company nor does the company, nor any of its shareholders, have plans to enter into a change of control or similar transaction.

Please see the amended contents of the Forepart the Prospectus 3on page 3 of the Form S-1/A in November 13, 2016.

3. We have reviewed your response to our prior comment 5. We note that you have nominal operations and, as of June 30, 2016, you had $196 in cash and cash equivalents, $2,207 in total assets, and $100 in revenues. Accordingly, you appear to be a "shell company" as defined by Rule 405 of the Securities Act. Please revise your disclosure in the prospectus cover page, prospectus summary, plan of distribution and elsewhere throughout the prospectus, as applicable, to indicate your shell company status. Also include the undertaking required by Item 512(a)(6) of Regulation S-K.

Please see the amended contents of the Forepart the Prospectus 7 on page 3 of the Form S-1/A in November 13, 2016.

Please see the amended contents of the Prospectus Summary 2 on page 6 of the Form S-1/A in November 13, 2016.

Please see the amended contents of the Undertaking on page 29 of the Form S-1/A in November 13, 2016.

Cover Page of Registration Statement

4. We note your response to our prior comment 7 and your revised disclosure that "the date on which the offer expires will be 25 days after the Form S-1 will be effective." Please revise your disclosure to delete this statement or confirm that, once the offering expires on the 25th day after effectiveness of the registration statement, you will file a post-effective amendment to deregister all unsold securities under the registration statement. If there were no sales made pursuant to the registration statement with those 25 days, please confirm that you will file an application to withdraw the registration statement pursuant to Rule 477 of the Securities Act. If you intend to continue to use the registration statement beyond the 25th day, please indicate by check mark that the securities being registered are to be offered on a continuous basis pursuant to Rule 415 under the Securities Act. Also include the undertakings required by Item 512(a) of Regulation S-K.

We removedthat "the date on which the offer expires will be 25 days after the Form S-1 will be effective."

5. Please delete the table after the delaying amendment disclosure.

We deleted the table after the delaying amendment disclosure.

Prospectus Cover Page

6. We note your response to our prior comment 8. We further note your disclosure in the use of proceeds section that "there is no minimum amount of proceeds that must be raised before the Corporation may use the proceeds of the offering." Please revise your disclosure on the prospectus cover page to indicate that this is a "best efforts offering." Additionally, please revise to indicate whether there are any arrangements to place the funds in an escrow, trust, or similar account. If you have not made any of these arrangements, state this fact and describe the effect on investors. Refer to Item 501(b)(8) of Regulation S-K.

Please see Please see the Cover Page8 on page 3 of the Form S-1/A in November 13, 2016.

Please see Please see the Use of Proceeds 4 and 10on page 7 of the Form S-1/A in November 13, 2016.

Prospectus Summary, page 6

7. We have reviewed your response to our prior comment 11. We do not believe you have provided reasonable basis for your disclosure that you will achieve a "3%-5% Annual Average Asset Return with low risk" pursuant to Item 10(b) of Regulation S-K. Please delete the disclosure here and throughout the document.

We deleted that we will achieve a "3%-5% Annual Average Asset Return with low risk" in Prospectus Summary and throughout the document.

8. Please revise your disclosure to discuss what you mean by "spot gold" and "spot silver."

The spot gold is the physical gold, and the spot silver is the physical silver.

Please see the Prospectus Summary5 on page 6 of the Form S-1/A in November 13, 2016.

9. We note your disclosure on page 22 where you state that "there aren't any conflicts of interest associated with running multiple businesses in the same industry." Please revise your disclosure to discuss all commitments of senior management, including how their time will be allocated between you, Lansdale, Inc., Blueville, Inc. and any other commitments. Also provide detailed disclosure on the procedures, if any, whereby investment opportunities are allocated among the competing entities.

Please see the Prospectus Summary 10 on page 6 of the Form S-1/A in November 13, 2016.

BluevilleInc is the managing company of all our public companies and our holding companies. All senior management's time will be allocated to Blueville Inc. BluevilleInc will manage all these companies, and the senior management's time will be allocated to each company according their need.

All our public companies will in trading in different markets, so the investment opportunities of each my public company will be decided by their markets.

Risk Factors, page 6

10. We note your disclosure in Note 2 to the financial statements where you state that, "[d]ue to the limited level of operations, the Company has not had to make material assumptions or estimates other than the assumption that the Company is a going concern." Please revise your disclosure in this section to discuss the risks related to the going concern opinion.

We changed the auditor. We removed that "[d]ue to the limited level of operations, the Company has not had to make material assumptions or estimates other than the assumption that the Company is a going concern."

11. Please revise your disclosure to provide the risks related to your management's lack of experience in the gold and silver trading business, including their lack of experience in running a public company.

Please see the Risk Factors 9 and 10 on page 7 of the Form S-1/A in November 13, 2016.

12. We note your disclosure that you "will try to raise funds in the future by some ways, to reduce the dependence on Lansdale Inc." To the extent you intend to raise funds in the future through the sale of stock, please discuss material risks related to the dilution that would be absorbed by existing security holders.

Please see the Risk Factors 2(6) on page 6 of the Form S-1/A in November 13, 2016.

Use of Proceeds, page 7

13. We refer to your third paragraph where you indicate that "if substantially less than the maximum proceeds are obtained, the priorities order that the proceeds will be used to p... any necessary expenditure." Please revise to give examples of these expenditures.

Please see the Use of Proceeds 3(1) on page 7 of the Form S-1/A in November 13, 2016.

14. We refer to your paragraph 5 where you state that "there isn't material amount of funds from sources other than this offering are to be used in conjunction with the proceeds from this offering." We further note your disclosure on page 5 that "Lansdale will continue to raise funds by any ways..." Please tell us whether Lansdale has raised any funds for you since inception. If so, please revise your disclosure to provide amounts and dates.

Now, Lansdale Inc didn't raise funds for the Corporation since its inception. Lansdale Inc will grant fund for the Corporation in the future.

Plan of Distribution, page 8

15. We note your response to our prior comment 13 where you state that "WanjunXie isn't subject to a statutory disqualification. WanjunXiedon't have any commissions or remuneration for this offering. WanjunXie isn't a broker-dealer. WanjunXie meets all conditions of the Safe Harbor for sales of Securities by officers." Please revise your disclosure to include these representations. Refer to Rule 3a4-1 of the Exchange Act.

Please see the Plan of Distribution 7on page 9 of the Form S-1/A in November 13, 2016.

16. We note your response to our prior comment 13 where you state that "Lansdale Inc will be only a buyer of these securiti..." We further note your disclosure in the summary section of the prospectus where you state that "Lansdale Inc. will continue to raise additional funds by any ways and continue to support the Corporation by granting funds or making loans without interest" and your disclosure in the "certain relationships and related transaction" section where you state that "[a]fter the registering in SEC will be effective, Lansdale Inc will purchase 96,000,000,000 Class A common shares of AchisonInc, it will be about 96% shares of Achison Inc. Lansdale Inc will pay the purchase by cash.' We refer you to the Amended Promising Letter filed as Exhibit 10 to the registration statement where Lansdale represented that it will continue to support you while your share price is less than $20/share and it will have no obligation to support you once your share price is more than $20/share. Please tell us whether the 96 billion common shares Lansdale intends to purchase from you will be in exchange for the grants and/or loans Lansdale makes to you. If so, please revise your disclosure to so state.

Please see the Plan of Distribution 8on page 9 of the Form S-1/A in November 13, 2016.

The Underwriters' Compensation and the offering Expenses, page 8

17. We note your disclosure that '[t]his is the table that sets out the nature of the underwriters' compensation and the amount of discounts and commissions to be paid to the underwriter for each security and in total." Please revise to provide the table or delete the disclosure.

We removed that "this is the table that sets out the nature of the underwriters' compensation and the amount of discounts and commissions to be paid to the underwriter for each security and in total."

Description of Securities to be registered, page 8

18. We note your disclosure that "the security has the cumulative voting rights." Please revise your disclosure to describe these rights and any conditions precedent to the exercise thereof.

We removed that "the security has the cumulative voting rights."

Please see the Description of Securities to be Registered 1(5)on page 9 of the Form S-1/A in November 13, 2016.

Interests of Named Experts and Counsel, page 9

19. Please revise to include legal counsel.

Please see the Interest of Named Experts and Counsel 2 on page 10 of the Form S-1/A in November 13, 2016.

Description of Business, page 9

20. We note your disclosure that you will use BullionVault System to be the trading vehicle. Please revise your disclosure to provide the brokerage fees and commission.

Please see the Description of Business 5 on page 10 of the Form S-1/A in November 13, 2016.

21. We note your disclosure that "the physical gold and silver will be stored in the professional storages in London, New York, Toronto, Zurich and Singapore." Please revise your disclosure to discuss the regulation of the warehouses, what controls are in place to ensure the commodities are safe, costs of warehousing, and whether the commodities will be insured, e.g., by the warehouse or by you. To the extent you have optional inspection rights, please so state.

Please see the Description of Business 9 on page 10 of the Form S-1/A in November 13, 2016.

Exhibits and Financial Statement Schedules, page 23

Exhibit 5

22. We refer to paragraph 3 where counsel states that it has assumed the legal competence or capacity of persons or entities to complete the execution of document. (Emphasis added). Please have counsel revise the opinion to delete the reference to "entities" or to carve out registrant.

Please see the Exhibit 5 on page 29 of the Form S-1/A in November 13, 2016.

23. We note assumptions (ii), (iii) and (iv) in paragraph 6. Counsel's opinion indicates that "the Registered Securities will be, when sold pursuant to the Prospectus, validly issu..." As such, the assumptions assume away the material facts underlying the opinion. Please have counsel delete these assumptions. Refer to Staff Legal Bulletin 19 (October 14, 2011) for guidance.

Please see the Exhibit 5 on page 29 of the Form S-1/A in November 13, 2016.

24. We note assumption (vii) in paragraph 7. Please have counsel revise the legal opinion to clarify that, as of the date of the opinion, you have a sufficient number of authorized shares.

Please see the Exhibit 5 on page 29 of the Form S-1/A in November 13, 2016.

25. We refer to the penultimate paragraph of the legal opinion where counsel states that "[t]his legal opinion has been prepared for the Company's benefit as an exhibit to the Company's Registration Statement already filed with SEC and may be relied upon by you and by persons entitled to rely upon the same pursuant to the applicable provisions of the Act solely for such purpose." (Emphasis added) It is unclear whether the reference to "persons" means purchasers of the securities in the offering. Please revise to delete this paragraph or revise to make clear that purchasers of the securities in the offering are entitled to rely on the opinion.

Please see the Exhibit 5 on page 29 of the Form S-1/A in November 13, 2016.

Wanjun Xie

Wanjun Xie
President

Achison Inc

Date: November 13, 2016

Mail Stop 3233

October 19, 2016

Via E -mail
Wanjun Xie
Chief Executive Officer
Achison Inc.
3906 Main Street
Suite 207
Flushing, NY 11354

Re: Achison, Inc.
Amendment No. 3 to Registration Statement on Form S -1
Filed September 22, 2016
  File No. 333-211051

Dear Mr. Xie:

We have reviewed your amended registration statement  and have the following
comments .  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an amen dment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have additional comments.   Unless  we note
otherwise , our references to prior comments are to comments in our [Month day, year] letter .

General

1. We note your response to our prior comment 2 and your revised disclosure that you are
“an emerging growth company” as defined in the Jumpstart Our Business Startups Act .
Please revise your registration statement to:

 Describe how and when a company may lose emerging growth company status;

 Briefly describe the various exemptions that are available to you, such as
exemptions from Section 404(b) of the Sarbanes -Oxley Act o f 2002 and Section
14A(a) and (b) of the Securities Exchange Act of 1934; and

Wanjun Xie
Achison Inc.
October 19, 2016
Page 2

 State your election under Section 107(b) of the JOBS Act:

o If you have elected to opt out of the extended transition period for
complying with new or revised accounting standards pursuant to Section
107(b), include a statement that the election is irrevocable; or

o If you have elected to use the extended transition period for complying
with new  or revised accounting standards under Section 102(b)(2), provide
a risk factor explaining that this election allows you to delay the adoption
of new or revised accounting standards that have different effective dates
for public and private companies until  those standards apply to private
companies.  Please state in your risk factor that, as a result of this election,
your financial statements may not be comparable to companies that
comply with public company effective dates.  Include a similar statement
in your critical accounting policy disclosures.

2. We note your response to our prior comment 4 where you state that you do not “have any
[plans] for merger and acquisition in the future.”  In the forepart of the prospectus, please
include an affirmative state ment to make clear that the company has no present plans to
be acquired or to merge with another company nor does the company, nor any of its
shareholders, have plans to enter into a change of control or similar transaction.

3. We have reviewed your respon se to our prior comment 5. We note that you have nominal
operations and, as of June 30, 2016, you had $196 in cash and cash equivalents, $2,207 in
total assets, and $100 in revenues. Accordingly, you appear to be a “shell company” as
defined by Rule 405 of  the Securities Act. Please revise your disclosure in the prospectus
cover page, prospectus summary, plan of distribution and elsewhere throughout the
prospectus, as applicable, to indicate your shell company status.  Also include the
undertaking required by Item 512(a)(6) of Regulation S -K.

Cover Page of Registration Statement

4. We note your response to our prior comment 7 and your revised disclosure that “the date
on which the offer expires will be 25 days after the Form S -1 will be effective.”  Please
revise your disclosure to delete this statement or confirm that, once the offering expires
on the 25th day after effectiveness of the registration statement, you will file a post -
effective amendment to deregister all unsold securities under the registratio n statement. If
there were no sales made pursuant to the registration statement with those 25 days, please
confirm that you will file an application to withdraw the registration statement pursuant
to Rule 477 of the Securities Act. If you intend to continu e to use the registration
statement beyond the 25th day, please indicate by check mark that the securities being
registered are to be offered on a continuous basis pursuant to Rule 415 under the
Securities Act. Also include the undertakings required by Ite m 512(a) of Regulation S -K.

Wanjun Xie
Achison Inc.
October 19, 2016
Page 3

 5. Please delete the table after the delaying amendment disclosure.

Prospectus Cover Page

6. We note your response to our prior comment 8. We further note your disclosure in the
use of proceeds section that “there is no minimum amount of proceeds that must be raised
before the Corporation may use the proceeds of the offering.” Please revise your
disclosure on the prospectus cover page to indicate that this is a “best efforts offering.”
Additionally, please revise to indicate whet her there are any arrangements to place the
funds in an escrow, trust, or similar account. If you have not made any of these
arrangements, state this fact and describe the effect on investors. Refer to Item 501(b)(8)
of Regulation S -K.

Prospectus Summary,  page 6

7. We have reviewed your response to our prior comment 11. We do not believe you have
provided reasonable basis for your disclosure that you will achieve a “3% -5% Annual
Average Asset Return with low risk” pursuant to Item 10(b) of Regulation S -K.  Please
delete the disclosure here and throughout the document.

8. Please r evise your disclosure to discuss  what you mean by “spot gold” and “spot silver.”

9. We note your disclosure on page 22 where you state that “there aren't any conflicts of
interest associated with running multiple businesses in the same industry.” Please revise
your disclosure to discuss all commitments of senior management, including how their
time will be allocated between you, Lansdale, Inc., Blueville, Inc. and any other
commitments. Also provide detailed disclosure on the procedures, if any, whereby
investment opportunities are allocated among the competing entities.

Risk Factors, pa ge 6

10. We note your disclosure in Note 2 to the financial statements where you state that, “[d]ue
to the limited level of operations, the Company has not had to make material assumptions
or estimates other than the assumption that the Company is a going con cern.” Please
revise your disclosure in this section to discuss the risks related to the going concern
opinion.

11. Please revise your disclosure to provide the risks related to your management’s lack of
experience in the gold and silver trading business, inc luding their lack of experience in
running a public company.

12. We note your disclosure that you “will try to raise funds in the future by some ways, to
reduce the dependence on Lansdale Inc.” To the extent you intend to raise funds in the
future through th e sale of stock, please discuss material risks related to the dilution that
would be absorbed by existing security holders.

Wanjun Xie
Achison Inc.
October 19, 2016
Page 4

 Use of Proceeds, page 7

13. We refer to your third paragraph where you indicate that “if substantially less than the
maximum proceeds a re obtained, the priorities order that the proceeds will be used to
pay… any necessary expenditure.” Please revise to give examples of these expenditures.

14. We refer to your paragraph 5 where you state that “there isn’t material amount of funds
from sources  other than this offering are to be used in conjunction with the proceeds from
this offering.” We further note your disclosure on page 5 that “Lansdale will continue to
raise funds by any ways…” Please tell us whether Lansdale has raised any funds for you
since inception. If so, please revise your disclosure to provide amounts and dates.

Plan of Distribution, page 8

15. We note your response to our prior comment 13 where you state that “Wanjun Xie isn't
subject to a statutory disqualification. Wanjun Xie don't have any commissions or
remuneration for this offering. Wanjun Xie isn't a broker -dealer. Wanjun Xie meets all
conditions of the Safe Harbor for sales of Securities by officers.”  Please revise your
disclosure to include these representations. Refer to Rule 3a4 -1 of the Exchange Act.

16. We note your response to our prior comment 13 where you state that “Lansdale Inc will
be only a buyer of these securities…”  We further note your disclosure in the summary
section of the prospectus where you state that  “Lansdale Inc. will continue to raise
additional funds by any ways and continue to support the Corporation by granting funds
or making loans without interest” and your disclosure in the “certain relationships and
related transaction” section where you sta te that “[a]fter the registering in SEC will be
effective, Lansdale Inc will purchase 96,000,000,000 Class A common shares of Achison
Inc, it will be about 96% shares of Achison Inc. Lansdale Inc will pay the purchase by
cash.” We refer you to the Amended Promising Letter filed as Exhibit 10 to the
registration statement where Lansdale represented that it will continue to support you
while your share price is less than $20/share and it will have no obligation to support you
once your share price is more tha n $20/share. Please tell us whether the 96 billion
common shares Lansdale intends to purchase from you will be in exchange for the grants
and/or loans Lansdale makes to you. If so, please revise your disclosure to so state.

The Underwriters' Compensation and the offering Expenses, page 8

17. We note your disclosure that ‘[t]his is the table that sets out the nature of the
underwriters' compensation and the amount of discounts and commissions to be paid to
the underwriter for each security and in total.” Pleas e revise to provide the table or delete
the disclosure.

Wanjun Xie
Achison Inc.
October 19, 2016
Page 5

 Description of Securities to be registered, page 8

18. We note your disclosure that “the security has the cumulative voting rights.” Please
revise your disclosure to describe these rights and any co nditions precedent to the
exercise thereof.

Interests of Named Experts and Counsel, page 9

19. Please revise to include legal counsel.

Description of Business, page 9

20. We note your disclosure that you will use BullionVault System to be the trading vehicle.
Please revise your disclosure to provide the brokerage fees and commission.

21. We note your disclosure that “the physical gold and silver will be stored in the
professional storages in London, New York, Toronto, Zurich and Singapore.” Please
revise your disclosure to discuss the regulation of the warehouses, what controls are in
place to ensure the commodities are safe, costs of warehousing, and whether the
commodities will be insured, e.g., by the warehouse or by you. To the extent you have
optional insp ection rights, please so state.

Exhibits and Financial Statement Schedules, page 23

Exhibit 5

22. We refer to paragraph 3 where counsel states that it has assumed the legal competence or
capacity of persons or entities  to complete the execution of document.  (Emphasis added).
Please have counsel revise the opinion to delete the reference to “entities” or to carve out
registrant.

23. We note assumptions (ii), (iii) and (iv) in paragraph 6. Counsel’s opinion indicates that
“the Registered Securities will be, when  sold pursuant to the Prospectus, validly
issued…” As such, the assumptions assume away the material facts underlying the
opinion. Please have counsel delete these assumptions. Refer to Staff Legal Bulletin 19
(October 14, 2011) for guidance.

24. We note assu mption (vii) in paragraph 7.  Please have counsel revise the legal opinion to
clarify that, as of the date of the opinion, you have a sufficient number of authorized
shares.

25. We refer to the penultimate paragraph of the legal opinion where counsel states t hat
“[t]his legal opinion has been prepared for the Company's benefit as an exhibit to the
Company's Registration Statement already filed with SEC and may be relied upon by you
and by persons entitled to rely upon the same pursuant to the applicable provis ions of the

Wanjun Xie
Achison Inc.
October 19, 2016
Page 6

 Act solely for such purpose.” (Emphasis added) It is unclear whether the reference to
“persons” means purchasers of the securities in the offering. Please revise to delete this
paragraph or revise to make clear that purchasers of the securities  in the offering are
entitled to rely on the opinion.

You may contact Paul Cline at (202) 551 -3851 or Wilson Lee at (202) 551 -3468 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Stacie Gorman at (202) 551 -3585 or me at (202) 551 -3673 with any other questions.

Sincerely,

 /s/ Folake Ayoola

Folake Ayoola
Senior Counsel , Office of Real
Estate and  Commodities

CORRESP
1
filename1.htm

CORRESP

CORRESP for the SEC letter of the Registration Satement on Form S-1

Achison INC
CIK: 0001672571
3906 Main Street, 207

Flushing, NY11354

September 20, 2016

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate and Commodities

100 F Street, N.E.

Washington, DC 20549

Attention:

     Sonia Gupta Barros

     Stacie Gorman

     Paul Cline

     Wilson Lee

Re: Achison Inc

    Amendment No. 2 to Registration Satement on Form S-1

    Filed August 11, 2016

    File No. 333-211051

The follow contents are in response to the SEC letter on September 7, 2016 for the Registration Satement on Form S-1:

General
1. Throughout the prospectus numerous statements in your disclosure are unclear because
they are not written in plain English or the concept is not fully described. Please review
your entire prospectus to ensure that your disclosure throughout is written in plain
English and the concepts that you describe are fully explained. See Rule 421(b) of
Regulation C. For example only, we note:

"Lansdale Inc. will continue to raise funds by any ways, and continue to support the
Corporation by granting funds or making loans without interest. Then, the Corporation
will continue to obtain the working capital, to driving the growth of the Corporation."
(page 5)

Please see the amended contents in page 6and page 16 of Form S-1/A on September 20, 2016.
"The Corporation is engaged in trading the spot gold and the spot silver. Gold and silver
market is close to direct competition in the international market. WanjunXie, who is
president of the Corporation, has found some special trading ways which are our business
secret, and we believes that we can achieve about 3%-5% Annual Average Assets Return
with low risk when we will be trading the spot gold and the spot silver by using these
special trading ways. But we won't guarantee to achieve about 3%-5% Annual Average
Assets Return with low risk when we will be trading the spot gold and the spot silver.
Any investors can see the financial statement quarterly and annually, to know if the
Corporation will profit or lose." (page 5)

Please see the amended contents in page 6 and page 11 of Form S-1/A on September 20, 2016.
"The Corporation isn't having or won't anticipates having within the next 12 months any
items in default or in breach of any note, loan, lease or other indebtedness or financing
arrangement requiring the corporation to make payments. The Corporation isn't having or
won't anticipates having within the next 12 months a significant amount of the
Company's trade payables have not been paid within the stated trade term." (page 6)

Please see the amended contents in page 7 of Form S-1/A on September 20, 2016.

2. It appears that you qualify as an "emerging growth company" as defined in the Jumpstart
Our Business Startups Act. If so, please disclose that fact in your filing.

Please see the amended contents of the Prospectus Summary in page 6 of Form S-1/A on September 20, 2016.

3. 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.

There aren't any written communications, as definedin Rule 405 under the Securities Act.

4. Section (a)(2) of Rule 419 defines a blank check company as a company that is issuing
penny stock that is "a development stage company that has no specific business plan or
purpose or has indicated that its business plan is to engage in a merger or acquisition with
an unidentified company or companies, or other entity." In discussing this definition in
the adopting release, the Commission stated that it would "scrutinize offerings for
attempts to create the appearance that the registrant has a specific business plan, in an
effort to avoid the application of Rule 419." See Securities Act Release No. 33-6932
(April 28, 1992).

Your disclosure indicates that you are a development stage company that intends to
invest in gold, silver, platinum, palladium, foreign currencies and stocks. Your
disclosure shows that you have minimal assets, no revenues, no operations, and no
contracts regarding the company's proposed products or services. We also note your
disclosure that this offering will not provide you with sufficient funds to provide the
proposed services. Additionally, we note that your website is not fully developed. In view of the foregoing, it appears that your proposed business may be commensurate in
scope with the uncertainty ordinarily associated with a blank check company. In view of
the foregoing, it appears that your proposed business may be commensurate in scope with
the uncertainty ordinarily associated with a blank check company.

Accordingly, please revise your disclosure throughout your registration statement to
comply with Rule 419 of Regulation C or supplementally provide a detailed explanation
as to why Rule 419 does not apply to this offering. If you believe that you do not fall
within the definition of a blank check company, appropriate disclosure to demonstrate
your status as a non-blank check company should be included in the prospectus as well as
a specific business plan. Please refer to Item 101(a)(2) of Regulation S-K. We offer the
following comments to help you revise your disclosure.

The Corporation has its special business plan for trading the spot gold and the spot silver, and its businesses is operated normally, at same time, the Corporation won't have any plan for merger and acquisition  in the future, so the Corporation isn't a blank check company.

Now, the Corporation has revenues, and its business is operated normally.

The Corporation won't lack cash, and the Corporation's capital can run its business, but the Corporation lacks capital for enlarging its businesses' dimension.

We only publish the contents which are requested to publish by the laws and the regulations in our websites.

Our businesses are quite sure,and the Corporation is a non-blank check company.

The specific business plan of the Corporation: Please see the amended contents of the Use of Proceeds 10 in page 7 of Form S-1/A on September 20, 2016.

5. It also appears that you are a shell company as defined in Rule 405 of Regulation C,
because you have nominal operations and total assets consisting solely of cash and cash
equivalents. Please revise your disclosure throughout to account for the implications of
being designated a shell company. Alternatively, please explain why you are not a shell
company.

The businesses of the Corporation are operated normally, and almost total assets of the Corporation are consisted by short term investment, so the Corporation isn't a shell company.

6. Throughout your registration statement you utilize industry jargon. For example only,
please provide a better explanation for "small part fund" and "important fund." If you
must include technical terms in the body of your prospectus that are understood only by
industry experts, you must make every effort to concisely explain these terms where you
first use them. In addition, please do not use technical terms or industry jargon in your
explanations.

We removed the phrases of "small part fund" and "important fund".

Please see the amended contents of the Risk Factors 3(1)  in page 7 of Form S-1/A on September 20, 2016.

Cover Page of Registration Statement

7. We note that your offering will continue for 45 days after the S-1 is effective and
therefore appears to be a continuous offering under Rule 415. We note, however, that
you did not check the box to indicate that you are engaging in a continuous offering
under Rule 415. Please revise or advise us as to why you believe Rule 415 is not
applicable.

Our offering will continue for 25 days after the S-1 is effective.

Please see the amended contents of the Cover Page 8 in page 6 of Form S-1/A on September 20, 2016.

Cover Page

8. Please ensure that your cover page does not exceed one page in length as required by
Item 501(b) of Regulation S-K. The cover page should be limited to information
required by Item 501 and other information that is key to an investment decision. Some
of the details of the offering may be more appropriate for the prospectus summary or the
body of the prospectus.

We have amended the contents of the Cover Page.

Please see the amended contents of the Cover Page 3 in page 3 of Form S-1/A on September 20, 2016.

9. We note your reference to your securities being "listed" on the OTC Markets. Please
revise to clarify that you will seek to have your shares quoted on the OTC Markets.

Please see the amended contents of the Cover Page 6 in page 3 of Form S-1/A on September 20, 2016.

10. We note paragraph 13 contains the dealer prospectus delivery obligation. Please move
this to the outside back cover page of the prospectus and ensure that it complies with the
requirements of Item 502 of Regulation S-K and Section 4(a)(3) of the Securities Act.

Please see the amended contents of the Outside Back Cover Page in page 5 of Form S-1/A on September 20, 2016.

Prospectus Summary, page 5

11. We note your disclosure that you are engaged in trading spot gold and spot silver and that
you believe your will achieve a "3% to 5% annual average asset return with low risk."
Please tell us your reasonable basis for this statement, which appears to be a projection.
Please also provide the disclosures regarding projections required by Item 10(b) of
Regulation S-K.

Please see the amended contents of the Prospectus Summary in page 6 of Form S-1/A on September 20, 2016.

12. We note your disclosure on page 18 that you intend to invest in gold, silver, platinum,
palladium, foreign currencies and stocks. Please reconcile this with your disclosure that
you intend to invest in spot gold and spot silver.

Please see the amended contents of the Directors, Executive Officers, Promoters and Control Persons in page 22 of Form S-1/A on September 20, 2016.

Plan of Distribution, page 8

13. We note your disclosure that Mr. Xie will be selling securities on your behalf. Please
explain how his activities will meet the safe harbor provisions set out in Rule 3a4-1 under
the Securities Exchange Act of 1934. Additionally, we note your disclosure on page 5
that Lansdale Inc. will continue to raise funds and support you. Please advise whether
Lansdale will be selling securities on your behalf in this offering or in the future, and if
so, whether it is a registered broker-dealer.

Wanjun Xie isn't subject to a statutory disqualification. Wanjun Xie don't have any commissions or remuneration for this offering. Wanjun Xie isn't a broker-dealer. Wanjun Xie meets all conditions of the Safe Harbor for sales of Securities by officers.

Lansdale Inc will be only a buyer of these securities, and it will be long term to hold these securities. Lansdale Inc will be only a shareholder. Lansdale won't be a broker-dealer.

14. We note your disclosure on page 18 that Lansdale Inc. will purchase 96,000,000 shares
using cash and properties. Please advise whether Lansdale has contractually committed
to purchasing these shares. Further, please advise what properties will be provided in
order to purchase these shares.

Lansdale doesn't have contractually committedto purchasing these shares.

Lansdale Inc must purchase the shares of Achison Inc by cash.

Please see the amended contents of the Plan of Distribution in page 22 of Form S-1/A on September 20, 2016.

Interests of Named Experts and Counsel, page 9

15. Please revise to identify your independent accountant as an expert.

Please see the amended contents of the Interests of Named Experts and Counsel in page 10 of Form S-1/A on September 20, 2016.

16. Please update your financial statements in accordance with Rule 8-08 of Regulation S-X
for the interim period ended June 30, 2016. Please also update your other financial
related information throughout your filing, including a discussion of the interim period
ended June 30, 2016 within your MD&A consistent with Item 303(b) of Regulation S-K.

Please see the amended contents of the Financial Statements in page 12 of Form S-1/A on September 20, 2016.

We have updated our other financial related information throughout our filing, including a discussion of the interim period ended June 30, 2016 within our MD&A consistent.

Description of Business, page 9

17. We note your disclosure that your "business isn't regulated by the U.S. Commodity
Futures Trading Commission and the National Futures Association." Please provide a
detailed legal analysis as to how you determined that your proposed business plan
exempts you from regulation by these entities.

The spot gold trading and the spot silver trading isn't regulated by Commodity Exchange Act.  The business of the Corporation is engaging trading the spot gold and the spot silver, so the businesses of the Corporation isn't regulated by the U.S. Commodity Futures Trading Commission and the National Futures Association.

Please see the amended contents of the Description of Business in page 11 of Form S-1/A on September 20, 2016.

Evaluation of Disclosure Controls and Procedures, page 17

Changes in Internal Controls over Financial Reporting and Statement, page 18

18. The disclosure controls and procedures and internal controls over financial reporting
sections are not required in your Form S-1. Please remove both of these sections from
your Form S-1. Alternatively, please tell us in detail how management's conclusions
regarding the effectiveness of your disclosure controls and procedures continue to be
appropriate given that:

You have one employee who does not appear to be an expert in U.S. GAAP;

You made your initial filing without audited financial statements

Other required disclosures noted in our comments are not originally included in your
filings.

Please see the amended contents of the Evaluation of Disclosure Controls and Procedures in page 21 of Form S-1/A on September 20, 2016.

Please see the amended contents of the Changes in Internal Controls over Financial Reporting and Statement in page 22 of Form S-1/A on September 20, 2016.

We are on the basis of the physical truth of the Corporation, and all financial data are on the basis of the audited financial statement, to finish the management's conclusions. We believe the effectiveness of our disclosure controls and procedures.

Directors, Executive Officers..., page 18

19. Please disclose the business experience of Mr. Xie and Ms. Li during the last five years,
including their principal occupations and employment, and the names and principal
businesses of any corporation or other organization in which such occupation and
employment were carried out. In addition, any directorships during the past five years
should be disclosed. Please see Item 401of Regulation S-K. For example only, we note
that Mr. Xie and Ms. Li are affiliated with Lemont Inc., Landsbay, Inc., Linton Inc.,
Larison Inc., Blueville, Inc. and Lansdale, Inc. Further, in an appropriate section, please
explain the relationship of these entities to you. Finally, please provide support for your
disclosure on page 9 that management has "more than 24 years management prior
experience related to [your] business."

The business experiences of Wanjun Xie and Liuyan Li during the past five years have been amended.

We have removed "more than 24 years management prior experience related to our business."

Please see the amended contents of the Directors, Executive Officers, Promoters and Control Persons in page 22 of Form S-1/A on September 20, 2016.

Part II - Information Not Required in Prospectus

20. Please clearly separate the disclosure in Part II of the registration statement from the
disclosure in Part I of the reg

Mail Stop 3233

September 7, 2016

Via E -mail
Wanjun Xie, Chief Executive Officer
Achison Inc.
3906 Main Street
Suite 207
Flushing, NY 11354

Re: Achison, Inc.
Amendment No. 2 to Registration Statement on Form S -1
Filed August 11, 2016
  File No. 333-211051

Dear Mr. Xie:

We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information.   If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.

General

1. Throughout the prospectus numerous statements in your disclosure are unclear because
they are not written in plain English or the concept is not fully described. Please review
your entire prospectus to ensure that your disclosure throughout is written in plain
English and the concepts that you describe are fully explained. See Rule 421(b) of
Regulation C. For example only, we note:

Wanjun Xie
Achison Inc.
September 7, 2016
Page 2

  “Lansdale Inc. will continue to raise funds by any ways, and continue to support the
Corporation by granting funds or making loans without interest. Then, the Corporation
will continue to obtain the working capita l, to driving the growth of the Corporation.”
(page 5)

 “The Corporation is engaged in trading the spot gold and the spot silver. Gold and silver
market is close to direct competition in the international market. Wanjun Xie, who is
president of the Corpora tion, has found some special trading ways which are our business
secret, and we believes that we can achieve about 3% -5% Annual Average Assets Return
with low risk when we will be trading the spot gold and the spot silver by using these
special trading way s. But we won't guarantee to achieve about 3% -5% Annual Average
Assets Return with low risk when we will be trading the spot gold and the spot silver.
Any investors can see the financial statement quarterly and annually, to know if the
Corporation will pro fit or lose.” (page 5)

 “The Corporation isn't having or won't anticipates having within the next 12 months any
items in default or in breach of any note, loan, lease or other indebtedness or financing
arrangement requiring the corporation to make payments . The Corporation isn't having or
won't anticipates having within the next 12 months a significant amount of the
Company's trade payables have not been paid within the stated trade term.” (page 6)

2. It appears that you qualify as an “emerging growth company ” as defined in the Jumpstart
Our Business Startups Act.   If so, please disclose that fact in your filing.

3. Please supplementally provide us with copies of all written communications, as defined
in Rule 405 under the Securities Act, that you , or anyone aut horized 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.

4. Section (a)(2) of Rule 419 defines a blank check company as a company that is issuing
penny stock that is “a development stage company that has no specific business plan or
purpose or has indicated that its business plan is to engage in a merger or acquisition with
an unidentified company or companies, or other entity.”  In discussi ng this definition in
the adopting release, the Commission stated that it would “scrutinize   offerings for
attempts to create the appearance that the registrant   has a specific business plan, in an
effort to avoid the application of Rule 419.”  See Secur ities Act Release No. 33 -6932
(April 28, 1992).

Your disclosure indicates that you are a development stage company that intends to
invest in gold, silver, platinum, palladium, foreign currencies and stocks.  Your
disclosure shows that you have minimal assets, no revenues, no operations,  and no
contracts regarding the company’s proposed products or services.  We also note your
disclosure that this offering will not provide you with sufficient funds to provide the
proposed services.  Additionally, we note  that your website is not fully developed. In

Wanjun Xie
Achison Inc.
September 7, 2016
Page 3

 view of the foregoing, it appears that your proposed business may be commensurate in
scope with the uncertainty ordinarily associated with a blank check company.  In view of
the foregoing, it appears that your proposed business may be commensurate in scope with
the uncertainty ordinarily associated with a blank check company.

Accordingly, please revise your disclosure throughout your registration statement to
comply with Rule 419 of Regulation C or supplementa lly provide a detailed explanation
as to why Rule 419 does not apply to this offering.  If you believe that you do not fall
within the definition of a blank check company, appropriate disclosure to demonstrate
your status as a non -blank check company shoul d be included in the prospectus as well as
a specific business plan.  Please refer to Item 101(a)(2) of Regulation S -K.  We offer the
following comments to help you revise your disclosure.

5. It also appears that you are a shell company as defined in Rule 4 05 of Regulation C,
because you have nominal operations and total assets consisting solely of cash and cash
equivalents. Please revise your disclosure throughout to account for the implications of
being designated a shell company. Alternatively, please exp lain why you are not a shell
company.

6. Throughout your registration statement you utilize industry jargon. For example only,
please provide a better explanation for “small part fund” and “important fund.” If you
must include technical terms in the body of your prospectus that are understood only by
industry experts, you must make every effort to concisely explain these terms where you
first use them. In addition, please do not use technical terms or industry jargon in your
explanations.

Cover Page of Regis tration Statement

7. We note that your offering will continue for 45 days after the S -1 is effective and
therefore appears to be a continuous offering under Rule 415.  We note , however,  that
you did not check the box to indicate that you are engaging in a co ntinuous offering
under Rule 415. Please revise or advise  us as to why you believe Rule 415 is not
applicable .

Cover Page

8. Please ensure that your cover page does not exceed one page in length as required by
Item 501(b) of Regulation S -K.  The cover page should be limited to information
required by Item 501 and other information that is key to an investment decision.  Some
of the details of the offering may be more appropriate for the prospectus summary or the
body of the prospectus.

9. We note your reference to your securities being “listed” on the OTC Markets.  Please
revise to clarify that you will seek to have your shares quoted on the OTC Markets.

Wanjun Xie
Achison Inc.
September 7, 2016
Page 4

10. We note paragraph 13 contains the dealer prospectus delivery obligation.  Please mov e
this to the outside back cover page of the prospectus and ensure that it complies with the
requirements of Item 502 of Regulation S -K and Section 4(a)(3) of the Securities Act.

Prospectus Summary, page 5

11. We note your disclosure that you are engaged in  trading spot gold and spot silver and that
you believe your will achieve a “3% to 5% annual average asset return with low risk.”
Please tell us your reasonable basis for this statement, which appears to be a projection.
Please also provide the disclosur es regarding projections required by Item 10(b) of
Regulation S -K.

12. We note your disclosure on page 18 that you intend  to invest in gold, silver, platinum,
palladium, foreign currencies and stocks.  Please reconcile this with your disclosure that
you int end to invest in spot gold and spot silver.

Plan of Distribution, page 8

13. We note your disclosure that Mr. Xie will be selling securities on your behalf.  Please
explain how his activities  will meet the safe harbor provisions set out in Rule 3a4 -1 under
the Securities Exchange Act of 1934 .  Additionally, we note your disclosure on page 5
that Lansdale Inc. will continue to raise funds and support you.   Please advise whether
Lansdale will be  selling securities on your behalf in this offering or in the future, and if
so, whether it is a registered broker -dealer.

14. We note your disclosure on page 18 that Lansdale Inc. will purchase 96,000,000 shares
using cash and properties.  Please advise whe ther Lansdale has contractually committed
to purchasing these shares.  Further, please advise what properties will be provided in
order to purchase these shares.

Interests of Named Experts and Counsel, page 9

15. Please revise to identify your independent ac countant as an expert.

16. Please update your financial statements in accordance with Rule 8 -08 of Regulation S -X
for the interim period ended June 30, 2016.   Please also update your other financial
related information throughout your filing, including a di scussion of the interim period
ended June 30, 2016 within your MD&A consistent with Item 303(b) of Regulation S -K.

Wanjun Xie
Achison Inc.
September 7, 2016
Page 5

 Description of Business, page 9

17. We note your disclosure that your “business isn't regulated by the U.S. Commodity
Futures Trading Commission and the National Futures Association.”  Please provide a
detailed legal analysis as to how you determined that your proposed business plan
exempts you from regulation by these entities.

Evaluation of Disclosure Controls and Procedures, page 17

Changes in Internal Controls over Financial Reporting and Statement, page 18

18. The disclosure controls and procedures and internal controls over financial reporting
sections are not required in your Form S -1.   Please remove both of these sections from
your Form S -1.   Alternatively, please tell us in detail how management’s conclusions
regarding the effectiveness of your disclosure controls and procedures continue to be
appropriate given that:

 You have one employee who does not appear to be an expert in U .S. GAAP;

 You made your initial filing without audited financial statements

 Other required disclosures noted in our comments are not originally included in your
filings.

Directors, Executive Officers …, page 18

19. Please disclose the business experience of Mr. Xie and Ms. Li during the last five years,
including their principal occupation s and employment, and the name s and principal
business es of any corporation or other organization in which such occupation and
employment were carried out. In addition, any directorships during the past five years
should be disclosed.  Please see Item 401of Regulation S -K.  For example only, we note
that Mr. Xie and Ms. Li are affiliated with Lemont Inc., Landsbay, Inc., Linton Inc.,
Larison Inc., Blueville, Inc. and Lansdale, Inc. Further, in an appropriate section, please
explain the relationship of these entities to you.  Finally, please provide support for your
disclosure on page 9 that management has “more than 24 years managemen t prior
experience related to [your] business.”

Part II – Information Not Required in Prospectus

20. Please clearly separate the disclosure in Part II of the registration statement from the
disclosure in Part I of the registration statement. Refer to Form S -1.

Wanjun Xie
Achison Inc.
September 7, 2016
Page 6

 Undertakings, page 19

21. Please include all of the required undertakings. Refer to Section 512 of Regulation S -K
for guidance.

Exhibits and Financial Statement Schedules, page 19

22. Please ensure that you file all exhibits required under Item 601 of R egulation S -K,
including, but not limited to, an opinion of counsel as to the legality of the securities you
are seeking to register.  Please also refer to Staff Legal Bulletin 19 for guidance regarding
the legal opinion.

23. Please revise to include consent from your independent accountant as required under Item
601(b)(23) of Regulation S -K.   A consent from your independent registered public
accounting firm states, if true, that the auditor consents to the use of its auditor’s report,
and other references to  the auditor, in this registration statement.   It is also signed and
currently dated by the auditor.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the informat ion the Securities Act of 1933 and
all applicable Securities Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures t hey have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement, please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceedi ng initiated by the Commission or any person under the federal
securities laws of the United States.

Wanjun Xie
Achison Inc.
September 7, 2016
Page 7

 Please refer to Rules 460 and 461 regarding requests for acceleration.  We will consider a
written request for acceleration of the effective date of t he registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

You may contact Paul Cline at (202)551 -3851 or Wilson Lee  at (202)551 -3468 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Stacie Gorman at (202)551 -3585 or me at (202)551 -3655 with any other questions.

Sincerely,

 /s/ Sonia Gupta Barros

Sonia Gupta  Barros
Assistant Director
        Office of Real Estate and
Commodities

Mail Stop 3233

July 26 , 2016

Via E -mail
Wanjun Xie , President and Director
Achison Inc.
3906 Main Street
Suite 207
Flushing, NY 11354

Re: Achison Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed  July 13 , 2016
 File No.  333-211051

Dear Mr. Xie :

Our preliminary review of your registration statement indicates that it fails in numerous
material respects to comply with the requirements of the Securities Act o f 1933, the rules and
regulations under that Act, and the requirements of the form  because  it does not appear that your
financial statements were audited in accordance with the standards of the Public Company
Accounting Oversight Board (United States) .  We will not perform a detailed examination of the
registration statement and we will not issue comments.   We suggest that you consider filing a
substantive amendment to correct the deficiencies.

If you were to request acceleration of the effective date of t he registration statement in its
present form, we would likely recommend that the Commission deny your request.

Sincerely,

 /s/ Sonia Gupta Barros

Sonia Gupta Barros
Assistant Director
        Office of Real Estate and
Commodities

May 10, 2016

Wanjun Xie , President and Director
Achison Inc.
3906 Main Street
Suite 207
Flushing, NY 11354

Re: Achison Inc.
 Registration Statement on Form S-1
 Filed  May 2, 2016
 File No.  333-211051

Dear Mr. Xie :

Our preliminary review of your registration statement indicates that it fails in numerous
material respects to comply with the requirements of the Securities Act of 1933, the rules and
regulations under that Act, and the  requirements of the form because it does not contain audited
financial statements in accordance with Article 8 of Regulation S -X.  We will not perform a detailed
examination of the registration statement and we will not issue comments.   We suggest that yo u
consider filing a substantive amendment to correct the deficiencies.

If you were to request acceleration of the effective date of the registration statement in its
present form, we would likely recommend that the Commission deny your request.

Sincerely,

 /s/ Sonia Gupta Barros

Sonia Gupta Barros
Assistant Director
Office of Real Estate and
Commodities