United States securities and exchange commission logo June 24, 2020 Koji Shinohara Chief Financial Officer, Treasurer and Secretary Kura Sushi USA, Inc. 17932 Sky Park Circle, Suite H Irvine, California 92614 Re: Kura Sushi USA, Inc. Form 10-K for the Fiscal Year Ended August 31, 2019 Filed November 26, 2019 File No. 1-39012 Dear Mr. Shinohara: We have completed our review of your filing. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Sincerely, Division of Corporation Finance Office of Trade & Services