June 4, 2019

Hajime Uba
Chairman and Chief Executive Officer
Kura Sushi USA, Inc.
17932 Sky Park Circle, Suite H
Irvine, CA 92614

       Re: Kura Sushi USA, Inc.
           Amendment No. 1 to
           Draft Registration Statement on Form S-1
           Submitted May 17, 2019
           CIK No. 0001772177

Dear Mr. Uba:

      We have reviewed your amended draft registration statement and have the
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

Amended Draft Registration Statement on Form S-1

Summary Historical Financial and Operating Data
Key Financial and Operational Metrics, page 13

1.     Please present with equal or greater prominence the comparable GAAP
margin to the non-
       GAAP measure "restaurant-level contribution margin" presented on pages
13, 50 and 57.
Business Trends, page 54

2.     Refer to your response to comment 10. Please disclose the "honeymoon
period" for
       restaurant openings in fiscal year 2018 and, to the extent material,
discuss any differences
       in the trends evidenced in 2018 compared to 2017. In this regard, we
note your
 Hajime Uba
Kura Sushi USA, Inc.
June 4, 2019
Page 2
         disclosures that the "honeymoon" period for your three restaurant
openings in fiscal year
         2017 ranged up to six months.
Management's Discussion and Analysis of Financial Condition and Results of
Comparable Restaurant Sales Growth, page 58

3.       Refer to your response to comment 10 and your revised disclosure on
page 60. We note
         that one and two restaurants underwent renovations in fiscal years
2018 and 2017,
         respectively. Please explain how the decline in comparable restaurant
sales growth from
         fiscal year 2017 to fiscal year 2018 is primarily due to the increase
in sales after a
         restaurant reopens from temporary closure for renovation. To the
extent this is because
         reopened restaurants similarly experience a "honeymoon period,"
clarify this and discuss
         the extent to which there is a material difference in the honeymoon
period for a renovated
         restaurant compared to a newly opened restaurant.
Results of Operations
Six Months Ended February 28, 2019 Compared to Six Months Ended February 28,
2018, page

4.       Please consider including a summary explanation for the reason for the
operating loss
         incurred in the most recent interim period so that investors may have
a better
         understanding of the trend of your results. Refer to Item 303 of
Regulation S-K and
         Release No. 33-8350 for guidance.
February 28, 2019 Unaudited Interim Financial Statements
Note 2. Basis of Presentation and Summary of Significant Accounting Policies
Recently Adopted Accounting Pronouncements, page F-29

5.     Refer to your disclosure of the adoption of ASC 606, Revenue from
Contracts with
       Customers. Please disclose, if true, you adopted the standard using the
       retrospective approach, as expected in your disclosure on page F-13.
Ensure you address
       all aspects of your adoption as specified in ASC 606-10-65-1,
particularly paragraphs d.2,
       h and i, as appropriate. For example, if applicable, disclose the
modified retrospective
       approach allows the standard to be applied retrospectively through a
cumulative catch up
FirstName LastNameHajime Uba adoption (and the amount of such), with
       adjustment recognized upon
Comapany NameKura Sushi USA, Inc.not restated and reported under the accounting
       financial statement information
June 4,in effect for2
        2019 Page those periods.
FirstName LastName
 Hajime Uba
FirstName LastNameHajime Uba
Kura Sushi USA, Inc.
Comapany NameKura Sushi USA, Inc.
June 4, 2019
Page 3
June 4, 2019 Page 3
FirstName LastName
       You may contact Beverly Singleton, Staff Accountant, at (202) 551-3328
or Doug Jones,
Staff Accountant, at (202) 551-3309 if you have questions regarding comments on
the financial
statements and related matters. Please contact J. Nolan McWilliams,
Attorney-Advisor, at (202)
551-3217 or Anne Nguyen Parker, Assistant Director, at (202) 551-3611 with any


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Corporation Finance
                                                          Office of
Transportation and Leisure
cc:      Aaron Seamon