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    LAURA
                                            ANTHONY, ESQ.

    CRAIG
    D. LINDER, ESQ.*

    JOHN
CACOMANOLIS, ESQ.**

    WWW.ALCLAW.COM

    WWW.SECURITIESLAWBLOG.COM

    Associates
    and OF COUNSEL:

    CHAD
                                            FRIEND, ESQ., LLM

    MICHAEL
    R. GEROE, ESQ., CIPP/US***

    JESSICA
    HAGGARD, ESQ. ****

    PETER
    P. LINDLEY, ESQ., CPA, MBA

    JOHN
    LOWY, ESQ.*****

    STUART
    REED, ESQ.

    LAZARUS
    ROTHSTEIN, ESQ.

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    ROVENSKAYA, ESQ.******

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    TULCHIN, ESQ. *******

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in CA, FL and NY

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****licensed
in Missouri

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in NY and NJ

******licensed
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*******licensed
in CA and HI (inactive in HI)

January
10, 2024

VIA
ELECTRONIC EDGAR FILING

Office
of Real Estate and Construction

Division
of Corporation Finance

Securities
and Exchange Commission

100
F. Street, N.E.

Washington,
D.C. 20549

    Re:
    Metros
                                            Development Co., Ltd.

    Amendment
    No. 3 to Registration Statement on Form F-1

    Filed
    December 26, 2023

    File
    No. 333-274696

Dear
Sir or Madam:

This
letter responds to the correspondence (“Comment Letter”) from the staff of the Division of Corporation Finance (the
“Staff”) of the Securities and Exchange Commission (the “SEC”) dated January 9, 2024 to Yoshihiro
Koshiba, Chief Executive Officer of Metros Development Co., Ltd. (the “Company”), providing a comment on the above-referenced
Amendment No. 3 to Registration Statement on Form F-1, filed on December 26, 2023 by the Company. We have included a narrative response
herein keyed to the comment of the Staff of the SEC set forth in the Comment Letter. We trust you shall deem the contents of this letter
responsive to your Comment Letter.

Amendment
3 to Registration Statement on Form F-1

Financial
Statements, page F-1

    1.
    Comment:
    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.

    Response:
    We acknowledge the Staff’s comment. However, we previously filed the relevant representation as allowed under Step 2 of
    the Instructions to Item 8.A.4 of Form 20-F with the SEC on December 1, 2023 as Exhibit 99.1 to Amendment No. 2 to our Registration
    Statement on Form F-1 (which appears as Exhibit 99.1 (hyperlinked) in the Exhibit Index (Item 8 of Part II) of Amendment No. 3 to
    our Registration Statement on Form F-1 filed with the SEC on December 26, 2023).

If
the Staff has any further comments regarding Amendment No. 3 to the registration statement on Form F-1, or any subsequent amendments
to the Company’s registration statement on Form F-1, please feel free to contact the undersigned.

    ANTHONY,
    LINDER & CACOMANOLIS, PLLC

    By:

    /s/
    Laura Anthony

    Laura
    Anthony, Esq.

    cc:
    Mark
    Rakip /U.S. Securities and Exchange Commission

    Kristina
    Marrone /U.S. Securities and Exchange Commission

    Catherine
    De Lorenzo /U.S. Securities and Exchange Commission

    Brigitte
    Lippmann /U.S. Securities and Exchange Commission

    Yoshihiro
    Koshiba /Metros Development Co., Ltd

    Craig
    D. Linder, Esq./Anthony, Linder & Cacomanolis, PLLC

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