0001599916-20-000134.txt : 20201130 0001599916-20-000134.hdr.sgml : 20201130 20201027091336 ACCESSION NUMBER: 0001599916-20-000134 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20201027 FILER: COMPANY DATA: COMPANY CONFORMED NAME: OFF Line International, Inc. CENTRAL INDEX KEY: 0001818152 STANDARD INDUSTRIAL CLASSIFICATION: COMMUNICATION SERVICES, NEC [4899] IRS NUMBER: 320620813 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 4-30-4F, YOTSUYA CITY: SHINJUKU-KU, JAPAN STATE: M0 ZIP: 160-0004 BUSINESS PHONE: 81-3-6369-3727 MAIL ADDRESS: STREET 1: 4-30-4F, YOTSUYA CITY: SHINJUKU-KU, JAPAN STATE: M0 ZIP: 160-0004 CORRESP 1 filename1.htm

October 27, 2020

VIA EDGAR TRANSMISSION

U.S. Securities and Exchange Commission

Division of Corporations Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: OFF Line International, Inc.

Registration Statement on Form S-1

Filed October 22, 2020

File No. 333-242143

To the men and women of the SEC:

Acceleration Request:

We, OFF Line International, Inc., (the ‘Registrant’) hereby request that the Securities and Exchange Commission take appropriate action to declare the above captioned Registration Statement effective at the requested date of October 29, 2020 at 4 PM Eastern Standard Time or as soon as practicable thereafter.

In connection with this request, the Company acknowledges 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 proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Date: October 27, 2020

/s/ Koichi Ishizuka

Koichi Ishizuka

Chief Executive Officer