January 31, 2020

Tie Li
Director and Chief Financial Officer
Leading Ideal Inc.
8th Floor, Block D, Building 8,
4th District of Wangjing East Garden,
Chaoyang District, Beijing 100102
People's Republic of China

       Re: Leading Ideal Inc.
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Filed January 17, 2020
           CIK No. 0001791706

Dear Mr. Li:

      We have reviewed your amended 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 amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
circumstances or do not believe an amendment is appropriate, please tell us why
in your

       After reviewing any amendment to your registration 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 January 2,
2020 letter.

Draft Registration Statement on Form F-1 Filed on January 20, 2020

21. Convertible Redeemable Preferred Shares and Warrants
Accounting for Preferred Shares, page F-52

1.     We note your response to prior comment number 17. Given that you do not
       identify the independent appraiser as an expert, please remove the
reference to the
       independent appraiser from the filing.
Exhibit 5.1, page i

2.     We note your reference to the company's register of members included in
the opinion
 Tie Li
Leading Ideal Inc.
January 31, 2020
Page 2
       section. Please expand your disclosure under "Description of Share
Capital   Ordinary
       Shares" to discuss the procedures and timing required to make
appropriate entries. Please
       include a statement in this section that the company will perform the
procedures necessary
       to register the shares in the register of members. We note that the
depositary will initially
       hold the ordinary shares underlying the ADSs. You should therefore
discuss the ability to
       seek rectification of the register of members, as necessary.
Exhibit 99.2, page ii

3.     Please reconcile, as necessary, your disclosure regarding the
enforceability of the VIE
       agreements in paragraph C.(1) with your disclosure in the registration
statement that not
       all of the equity interest agreements have been registered. See the
disclosure in the risk
       factor on page 37, "Our ability to enforce the equity pledge
       You may contact Ernest Greene, Staff Accountant at (202) 551-3733 or
Kevin Stertzel,
Staff Accountant at (202) 551-3723 if you have questions regarding comments on
the financial
statements and related matters. Please contact Sherry Haywood, Staff Attorney
at (202) 551-
3345 or Asia Timmons-Pierce, Special Counsel at (202) 551-3754 with any other

FirstName LastNameTie Li
                                                             Division of
Corporation Finance
Comapany NameLeading Ideal Inc.
                                                             Office of
January 31, 2020 Page 2
cc:       Z. Julie Gao
FirstName LastName