SEC Comment Letter 0000000000-23-011952 to Metros Development Co., Ltd. (MTRS) (CIK 0001984076)
Metros Development Co., Ltd. (MTRS) (CIK 0001984076)
Date: Nov. 1, 2023 · CIK: 0001984076 · Accession: 0000000000-23-011952
AI Filing Summary & Sentiment
File numbers found in text: 333-274696
Letter
United States securities and exchange commission logo November 1, 2023 Yoshihiro Koshiba Chief Executive Officer Metros Development Co., Ltd. Ginza Sanno Building 7F 4-10-10, Ginza, Chuo-ku Tokyo 1040061 Japan Re:Metros Development Co., Ltd. Amendment No. 1 to Registration Statement on Form F-1 Filed October 19, 2023 File No. 333-274696 Dear Yoshihiro Koshiba: We have reviewed your amended registration statement and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our 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. Form F-1 Description of Business, page 48 1.We note your revised disclosure that you plan to use approximately 40% of the net amount of offering proceeds for the development and marketing of the new real estate crowdfunding platform. Please discuss in greater detail your specific plan for the crowdfunding platform, such as timing for the planned phases of development and marketing, the associated costs, how you expect to generate revenues from the platform, the period you expect revenues to commence, and any risks associated with completing the platform.
FirstName LastNameYoshihiro Koshiba Comapany NameMetros Development Co., Ltd. November 1, 2023 Page 2 FirstName LastName Yoshihiro Koshiba Metros Development Co., Ltd. November 1, 2023 Page 2 Please contact Mark Rakip at 202-551-3573 or Kristina Marrone at 202-551-3429 if you have questions regarding the financial statements and related matters. Please contact Catherine De Lorenzo at 202-551-3772 or Brigitte Lippmann at 202-551-3713 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Craig D. Linder, Esq.
Show Raw Text
United States securities and exchange commission logo
November 1, 2023
Yoshihiro Koshiba
Chief Executive Officer
Metros Development Co., Ltd.
Ginza Sanno Building 7F
4-10-10, Ginza, Chuo-ku
Tokyo 1040061
Japan
Re:Metros Development Co., Ltd.
Amendment No. 1 to Registration Statement on Form F-1
Filed October 19, 2023
File No. 333-274696
Dear Yoshihiro Koshiba:
We have reviewed your amended registration statement and have the following comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe our 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.
Form F-1
Description of Business, page 48
1.We note your revised disclosure that you plan to use approximately 40% of the net
amount of offering proceeds for the development and marketing of the new real estate
crowdfunding platform. Please discuss in greater detail your specific plan for the
crowdfunding platform, such as timing for the planned phases of development and
marketing, the associated costs, how you expect to generate revenues from the platform,
the period you expect revenues to commence, and any risks associated with completing
the platform.
FirstName LastNameYoshihiro Koshiba
Comapany NameMetros Development Co., Ltd.
November 1, 2023 Page 2
FirstName LastName
Yoshihiro Koshiba
Metros Development Co., Ltd.
November 1, 2023
Page 2
Please contact Mark Rakip at 202-551-3573 or Kristina Marrone at 202-551-3429 if you
have questions regarding the financial statements and related matters. Please contact Catherine
De Lorenzo at 202-551-3772 or Brigitte Lippmann at 202-551-3713 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Craig D. Linder, Esq.