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                           October 5, 2020

       Kouji Eguchi
       Chief Executive Officer
       Medirom Healthcare Technologies Inc.
       2-3-1 Daiba, Minato-ku
       Tokyo 135-0091, Japan

                                                        Re: Medirom Healthcare
Technologies Inc.
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted on
September 11, 2020
                                                            CIK 0001819704

       Dear Mr. Eguchi:

              We have reviewed your draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Draft Registration Statement on Form F-1

       Selected Consolidated Financial Information and Operating Data
       Reconciliation of non-GAAP measures, page 43

   1.                                                   You present a
reconciliation of the non-GAAP measure Adjusted EBITDA to operating
                                                        income. Please tell us
your consideration of the guidance in Question 103.02 of the Non-
                                                        GAAP Compliance and
Disclosure Interpretations related to considering net income as the
                                                        most directly
comparable GAAP financial measure.
 Kouji Eguchi
FirstName  LastNameKouji EguchiInc.
Medirom Healthcare Technologies
Comapany
October    NameMedirom Healthcare Technologies Inc.
        5, 2020
October
Page 2 5, 2020 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Comparison of the Results for the Years Ended December 31, 2019 and December
31, 2018,
page 51

2.       Please expand your disclosure to explain how the change in the number
of customers has
         affected your sales per customer key performance indicator in 2019.
3.       Please provide quantified discussions to separately explain the
changes in your revenues
         from and cost of revenues associated with directly-operated salon
operations, franchising
         activities, and other business between the reporting periods.
4.       Please provide quantified explanations for the material changes in
your consolidated
         statement of income items, such as selling, general, and
administration expenses,
         impairment loss on long-lived assets, interest expense, gain from
bargain purchase, other
         income, net, and income tax expense, between reporting periods.
Business
Company Overview, page 62

5.       Please define the term "customer management system." In this regard,
we note your
         disclosure that "[s]ince we introduced the customer management system
in 2010, we have
         served more than 1.57 million customers and in 2019, we served an
average 59,000
         customers per month."
6.       Please explain why "[you] believe COVID-19 has increased customer
realization." In this
         regard, we note your disclosure that "[t]he outbreak and associated
restrictions that have
         been implemented have had a material adverse impact on the Company   s
business and
         cash flow from operations, similar to many businesses."
Relaxation Salon Segment, page 63

7.       To provide additional context for investors and balance your
disclosure, please further
         discuss the extent to which the number of salons evidences any
material known trends or
         uncertainties. For example, it appears that the number of salons in
your table on page
         64 grew at a lower percentage year-over-year.
Our Growth Strategy, page 72

8.       Please further discuss the material assumptions and estimates
underlying your belief
         that "the Japanese market has a capacity for approximately 1,000
salons in suitable real
         estate that fits the underwriting requirements for [y]our business."
In this regard, we note
         your disclosure on page 66 that "[y]our midterm goal is to have 1,000
salons nationwide
         and become the number one salon network in Japan."
9.       We note your disclosure throughout the registration statement that you
intend to grow
         your business to new markets, particularly in the United States.
Please expand your
 Kouji Eguchi
FirstName  LastNameKouji EguchiInc.
Medirom Healthcare Technologies
Comapany
October    NameMedirom Healthcare Technologies Inc.
        5, 2020
October
Page 3 5, 2020 Page 3
FirstName LastName
         disclosure to include a more detailed discussion of the costs involved
in your proposed
         strategic plans, including any material commitments for capital
expenditures and proposed
         sources of funding. In this regard, we note your disclosure that "[i]n
the United States, we
         have developed and continue to sharpen our pipeline of operating
partners in the
         bodywork and physical therapy industry."
Our Competitive Strengths, page 74

10.      We note your disclosure that "[you] own and run [y]our own job portal
website, targeting
         prospective therapist candidates...[the] website has surpassed 11,000
pageviews shortly
         after launch and has already contributed over 179 suitable candidates
as of June 30,
         2020.    To provide additional context for investors please quantify,
if possible, the
         percentage of new employees that have been hired using your website.
In this regard, we
         note your disclosure that "[t]his digital solution to recruiting is
expected to reduce [y]our
         hiring cost otherwise paid to headhunters and manpower agents, by
approximately
         JPY10,000,000 (US$92,790) in FY 2020."
Regulation of Our Industry
Regulations Governing Dispatched Employees for Franchisees, page 83

11.      Please clarify if Medirom Human Resources Inc. has the required worker
dispatch
         license. In this regard, we note your disclosure that    MHR is
required to obtain a worker
         dispatch license from the Ministry of Health, Labor and Welfare of
Japan under the
         Dispatch Act.
Regulations Governing Prepaid Cards, page 83

12.      We note your disclosure regarding prepaid cards and the Outstanding
Amount that must
         be paid to the Legal Affairs Bureau. If material, please consider
quantifying such amount.
Consolidated Statements of Income, page F-4

13.      We note that you recognize revenues from services, sublease rental and
other activities.
         Please tell us your consideration of the guidance in Rule 5-03.1 of
Regulation S-X that
         requires separate presentation of revenues and costs associated with
services, rental
         income, and other activities.
Notes to Consolidated Financial Statements
1. Basis of Presentation and Summary of Significant Accounting Policies
Revenue Recognition, page F-15

14.      We note that you record rental income for operating leases on
properties subleased to
         franchisees as franchise revenue. Please provide us with reference to
the authoritative
         literature that supports your accounting.
 Kouji Eguchi
Medirom Healthcare Technologies Inc.
October 5, 2020
Page 4


General

15.      Please disclose the basis for all your assertions about your
competitive position within
         your industry. If you do not have appropriate independent support for
a statement, please
         revise the language to make clear that this is your belief based upon
your experience in the
         industry, if true. For example, please disclose the basis for your
assertion that "[you
         have] lower employee turnover rates than [y]our competitors."
       You may contact Suying Li at 202-551-3335 or Donna Di Silvio at
202-551-3202 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jennifer Lopez-Molina at 202-551-3792 or Lilyanna Peyser at
202-551-3222 with any
other questions.



FirstName LastNameKouji Eguchi                                 Sincerely,
Comapany NameMedirom Healthcare Technologies Inc.
                                                               Division of
Corporation Finance
October 5, 2020 Page 4                                         Office of Trade
& Services
FirstName LastName