SecProbe.io

CORRESP
1
filename1.htm

February
20, 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. (the “Company”)

    Registration
    Statement on Form F-1

    File
    No. 333-274696 (the “Registration Statement”)

Dear
Ms. De Lorenzo and Ms. Lippmann:

In
accordance with Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, (the “Act”),
we hereby join the Company’s request for acceleration of the above-referenced Registration Statement, requesting effectiveness
for 5:00 p.m., Eastern Time, on Thursday, February 22, 2024, or as soon thereafter as practicable.

Pursuant
to Rule 460 under the Act, we wish to advise you that the underwriters have distributed as many copies of the Preliminary Prospectus
dated December 26, 2023 to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution
of the Preliminary Prospectus.

The
undersigned, as the representatives of the several underwriters, represent that the several underwriters have and will comply with the
requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

Please
contact Lou Bevilacqua of Bevilacqua PLLC, counsel of the representatives of the underwriters, at 202-869-0888 (ext. 100) to provide
notice of effectiveness, or if you have any questions or concerns regarding the foregoing. We appreciate your assistance in this matter.

[Signature
page follows]

    Very
    truly yours,

    As
    representatives of the underwriters

    Boustead
    Securities, LLC

    EF
    Hutton LLC

    By:
    Boustead
    Securities, LLC

    By:
    /s/
    Keith Moore

    Name:
    Keith
    Moore

    Title:
    Chief
    Executive Officer