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                            April 3, 2024

       Kazusa Aranami
       Chief Executive Officer
       BloomZ Inc.
       Toyo Recording 1F, 4-5-19 Akasaka
       Minato-ku, Tokyo 107-0052
       Japan

                                                        Re: BloomZ Inc.
                                                            Amendment No. 2 to
Registration Statement on Form F-1
                                                            Filed March 20,
2024
                                                            File No. 333-275223

       Dear Kazusa Aranami:

            We have reviewed your amended registration statement and have the
following
       comment(s).

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our January 16, 2024
letter.

       Amendment No. 2 to Form F-1 filed March 20, 2024

       General

   1.                                                   We note that the size
of the resale component is double the size of the primary offering.
                                                        Please tell us why you
are registering the resale offering at this time and how you
                                                        determined the number
of ordinary shares being registered in connection with the resale
                                                        offering. Please also
disclose the details of the transaction(s) in which the selling
                                                        shareholders received
the shares covered by the resale prospectus and the length of time
                                                        the selling
shareholders have held the shares, with a view to understanding whether the
                                                        resale portion of the
offering should be deemed an indirect primary being conducted by or
                                                        on behalf of the
issuer, consistent with Question 612.09 of our Securities Act Rule
                                                        Compliance and
Disclosure Interpretations.
 Kazusa Aranami
BloomZ Inc.
April 3, 2024
Page 2
2.    Revise to disclose the natural person(s) that exercise voting and/or
dispositive power over
      the shares held by the entities listed on page Alt-3 and in the
footnotes. Please also
      disclose whether any of the natural persons have had a material
relationship with the
      company or any of its predecessors or affiliates within the past three
years. Refer to
      Question 140.02 of our Regulation S-K Compliance and Disclosure
Interpretations.
       Please contact Tony Watson at 202-551-3318 or Rufus Decker at
202-551-3769 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jenna Hough at 202-551-3063 or Erin Jaskot at 202-551-3442 with any
other questions.



                                                           Sincerely,
FirstName LastNameKazusa Aranami
                                                           Division of
Corporation Finance
Comapany NameBloomZ Inc.
                                                           Office of Trade &
Services
April 3, 2024 Page 2
cc:       Ying Li
FirstName LastName