SEC Comment Letter 0000000000-24-000289 to Metros Development Co., Ltd. (MTRS) (CIK 0001984076)
Metros Development Co., Ltd. (MTRS) (CIK 0001984076)
Date: Jan. 9, 2024 · CIK: 0001984076 · Accession: 0000000000-24-000289
AI Filing Summary & Sentiment
File numbers found in text: 333-274696
Letter
United States securities and exchange commission logo January 9, 2024 Yoshihiro Koshiba Chief Executive Officer Metros Development Co., Ltd. Tolerance Ginza Building 6F 3-9-7, Ginza, Chuo-ku Tokyo 1040061 Japan Re:Metros Development Co., Ltd. Amendment No. 3 to Registration Statement on Form F-1 Filed December 26, 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 a 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. Amendment 3 to Registration Statement on Form F-1 Financial Statements, page F-1 1.We note that your registration statement is an initial public offering, and the current audited financial statements are older than 12 months. Please clarify how you complied with the requirements of paragraph A(4) of Item 8 of Form 20-F. Revise to either update your audited financial statements or include the relevant representation as allowed under Step 2 of the Instructions to Item 8.A.4 of Form 20-F.
FirstName LastNameYoshihiro Koshiba Comapany NameMetros Development Co., Ltd. January 9, 2024 Page 2 FirstName LastName Yoshihiro Koshiba Metros Development Co., Ltd. January 9, 2024 Page 2 Please contact Mark Rakip at 202-551-3573 or Kristina Marrone at 202-551-3429 if you have questions regarding comments on 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
January 9, 2024
Yoshihiro Koshiba
Chief Executive Officer
Metros Development Co., Ltd.
Tolerance Ginza Building 6F
3-9-7, Ginza, Chuo-ku
Tokyo 1040061
Japan
Re:Metros Development Co., Ltd.
Amendment No. 3 to Registration Statement on Form F-1
Filed December 26, 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 a 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.
Amendment 3 to Registration Statement on Form F-1
Financial Statements, page F-1
1.We note that your registration statement is an initial public offering, and the current
audited financial statements are older than 12 months. Please clarify how you
complied with the requirements of paragraph A(4) of Item 8 of Form 20-F. Revise to
either update your audited financial statements or include the relevant representation as
allowed under Step 2 of the Instructions to Item 8.A.4 of Form 20-F.
FirstName LastNameYoshihiro Koshiba
Comapany NameMetros Development Co., Ltd.
January 9, 2024 Page 2
FirstName LastName
Yoshihiro Koshiba
Metros Development Co., Ltd.
January 9, 2024
Page 2
Please contact Mark Rakip at 202-551-3573 or Kristina Marrone at 202-551-3429 if you
have questions regarding comments on 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.