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CORRESP
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Metros
Development Co., Ltd.

Tolerance
Ginza Building 6F

3-9-7,
Ginza, Chuo-ku

Tokyo
1040061, Japan

January
25, 2024

VIA
EDGAR

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Real Estate & Construction

100
F Street, N.E.

Washington,
D.C. 20549

    Attention:
    Catherine
    De Lorenzo

    Brigitte
    Lippmann

    Re:
    Metros Development Co., Ltd.

    Withdrawal of Acceleration Request for Registration
    Statement on Form F-1

    File No. 333-274696

Dear
Ms. De Lorenzo and Ms. Lippmann:

Reference
is made to our letter, dated January 23, 2024, in which we requested acceleration of the effective date of the above referenced Registration
Statement to 4:00 p.m., Eastern Time, on January 25, 2024. We are no longer requesting that such Registration Statement be declared effective
at such time, and we hereby formally, and with immediate effect, withdraw our request for acceleration of the effective date.

    Very truly yours,

    Metros Development Co., Ltd.

    By:
    /s/ Yoshihiro
    Koshiba

    Yoshihiro Koshiba

    Chief Executive Officer

cc:
Craig D. Linder, Esq.