August 2, 2024

Shinichiro Haga
Lead Executive Officer and Senior General Manager, Corporate Strategy
Asahi Kasei Corporation
1-1-2 Yurakucho, Chiyoda-ku
Tokyo, Japan 100-0006

       Re: Asahi Kasei Corporation
           Calliditas Therapeutics AB
           Schedule TO-T/A filed August 1, 2024 by Asahi Kasei Corporation
           File No. 005-91523
Dear Shinichiro Haga:

       We have reviewed your filing and have the following comment.

        Please respond to this comment by providing the requested information
or advise us as
soon as possible when you will respond. If you do not believe our comment
applies to your facts
and circumstances, please tell us why in your response.

       After reviewing your response to this comment, we may have additional
comments.

Schedule TO-T/A filed August 1, 2024
Questions and Answers About the U.S. Offer, page 3

1.     We note your response to comment 3 in our prior comment letter. It
continues to be
       unclear whether you are reserving the right to rely on the guidance
provided in Section
       II.C.5 of SEC Release No. 34-58597 (Sept. 19, 2008). If so, the offer
materials must be
       revised to comply with the conditions to reliance on that guidance, and
you should
       describe in your response letter how you will satisfy the procedural
requirements to rely
       on it, including with respect to the requirement that the offer remain
open for at least five
       U.S. business days after reducing the minimum offer condition. In this
regard, we note
       that you have not provided for a subsequent offering period. If you do
not intend to rely
       on the guidance, note that any change in the minimum offer condition
below the current
       90% minimum needed to conduct a second-step    squeeze out    under
Swedish law would
       constitute a material change requiring that the offer remain open (with
withdrawal rights)
       for at least five U.S. business days after the change.
        We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
 August 2, 2024
Page 2

      Please direct any questions to Blake Grady at 202-551-8573.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Mergers &
Acquisitions