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United States securities and exchange commission logo
January 3, 2024
Fareed Aljawhari
Chief Executive Officer
Micropolis Holding Company
Warehouse 1, Dar Alkhaleej Building
Dubai Production City, Dubai, UAE
Re:Micropolis Holding Company
Registration Statement on Form F-1
Filed December 22, 2023
File No. 333-276231
Dear Fareed Aljawhari:
            We have reviewed your registration statement and have the following comment(s).
            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.
Registration Statement on Form F-1 filed December 22, 2023
Summary Financial Information, page 14
1.We note from your response to comment 8, that you have removed the US Dollar amounts
from the December 31, 2022 financial information. Please also remove the US Dollar
translation amounts related to the six months ended June 30, 2022. A convenience
translation may be presented only for the most recent fiscal year and any subsequent
interim period.
Our Major Suppliers, page 81
2.We note your revisions in response to comment 15. Please revise to reinsert the identity of
Supplier A and please explain why Siemens Industry Software has been removed from the
table.

 FirstName LastNameFareed Aljawhari
 Comapany NameMicropolis Holding Company
 January 3, 2024 Page 2
 FirstName LastName
Fareed Aljawhari
Micropolis Holding Company
January 3, 2024
Page 2
Compensation, page 97
3.Please update your compensation disclosure as of fiscal year ended December 31, 2023.
Financial Statements
Index to Combined Financial Statements, page F-1
4.Pursuant to Item 8.A.4 of Form 20-F, please provide audited financial statements that are
no more than twelve months old. Alternatively, to the extent you meet the 15-month
criteria outlined in Instruction 2 to Item 8.A.4, please file the necessary representations as
an exhibit to the registration statement.
5.We note that you include the interim unaudited financial statements for the six months
ended June 30, 2023 alongside the audited financial statements for the years ended
December 31, 2022 and 2021. Additionally, the notes to the financial statements relate to
both the interim period ended June 30, 2023 and the audited periods ended December 31,
2022 and 2021. In light of the fact that the interim amounts are unaudited, please revise to
separately present the interim statements and notes to the financial statements.
Balance Sheet, page F-3
6.We note your response to comment 18. You indicate that you removed the relevant
statement that the financial statements were authorized for issue on April 26, 2023. Please
revise or tell us where you have disclosed the date when the financial statements were
authorized for issue and who gave that authorization. Refer to paragraph 17 of IAS 10.
Statements of Comprehensive Income, page F-4
7.We note your response to comment 19 and your revised disclosures on page F-4 and F-25.
Please revise your disclosure pursuant to paragraph 70 of IAS 33 to include but not
limited to the amounts used as the numerators and the weighted average number of
ordinary shares used as the denominators in calculating basic and diluted earnings per
share for all periods presented. We note your revision to Note 22 to present new issuances
of your ordinary shares which happened after the reporting date of the financial
statements. Please tell us what consideration you gave to paragraph 64 of IAS 33
regarding retrospective adjustments.
Exhibits
8.Please refile your exhibits in the proper text-searchable format. Please refer to Item 301 of
Regulation S-T.

 FirstName LastNameFareed Aljawhari
 Comapany NameMicropolis Holding Company
 January 3, 2024 Page 3
 FirstName LastName
Fareed Aljawhari
Micropolis Holding Company
January 3, 2024
Page 3
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Ernest Greene at 202-551-3733 or Claire Erlanger at 202-551-3301 if you
have questions regarding comments on the financial statements and related matters. Please
contact Patrick Fullem at 202-551-8337 or Erin Purnell at 202-551-3454 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Lawrence Venick