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                             August 3, 2021

       Mike Logozzo
       Chief Financial Officer
       ReAlpha Asset Management Inc
       6515 Longshore Loop, Suite 100
       Dublin, OH 43017

                                                        Re: ReAlpha Asset
Management Inc
                                                            Amendment No. 2 to
                                                            Offering Statement
on Form 1-A
                                                            Filed July 13, 2021
                                                            File No. 024-11523

       Dear Mr. Logozzo:

             We have reviewed your amended offering 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 offering 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 offering 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 July
6, 2021 letter.

       Amendment No. 2 to Offering Statement on Form 1-A filed July 13, 2021

       General

   1.                                                   We note your responses
to comments 1 and 2. Please provide us a more detailed analysis
                                                        explaining how you
intend to comply with Regulation CF. In addition, please tell us more
                                                        specifically how you
intend to comply with the requirements for funding portals in light of
                                                        your plan to integrate
your M3 Platform with the broker-dealer   s own Regulation CF
                                                        compliant platform.
 Mike Logozzo
FirstName  LastNameMike Logozzo
ReAlpha Asset  Management Inc
Comapany
August     NameReAlpha Asset Management Inc
       3, 2021
August
Page 2 3, 2021 Page 2
FirstName LastName
Financial Statements
Note 1: Nature of Operations, page F-8

2.       Please tell us if your parent company or an affiliate has purchased
any additional
         properties subsequent to your inception, on your behalf. We refer you
to Rule 8-06 of
         Regulation S-X.
Note 5: Cash and Restricted Cash, page F-12

3.       We note your disclosure stating that restricted cash can represent a
cash deposit or funds
         in escrow, for properties being acquired. Please tell us if you have
any probable property
         acquisitions. Refer to Rule 8-06 of Regulation S-X.
        You may contact Babette Cooper at 202-551-3396 or Shannon Menjivar at
202-551-3856
if you have questions regarding comments on the financial statements and
related
matters. Please contact Jonathan Burr at 202-551-5833 or Jennifer Gowetski at
202-551-3401
with any other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Real
Estate & Construction