SecProbe.io

CORRESP
1
filename1.htm

December
20, 2024

VIA
EDGAR

Securities
and Exchange Commission

Division
of Corporation Finance

Office
of Manufacturing

100
F Street, N.E.

Washington,
D.C. 20549

Attention: Bradley
                                            Ecker & Jennifer Angelini

Re: PicoCELA
                                            Inc.

  Registration
                                            Statement on Form F-1, as amended

  File
                                            No. 333- 282931

Ladies
and Gentlemen:

Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned
hereby joins in the request of PicoCELA Inc. that the effective date of the above-referenced Registration Statement be accelerated so
as to permit it to become effective at 4:00 p.m., Eastern Time, on December 20, 2024, or as soon thereafter as practicable, or at such
other time as the Company or its outside counsel, Hunter Taubman Fischer & Li LLC, request by telephone that such Registration Statement
be declared effective.

Pursuant
to Rule 460 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended,
please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate in the distribution
of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure adequate distribution
of the preliminary prospectus.

The
undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange
Act of 1934, as amended.

*
* *

[Signature
Page Follows]

  Very truly yours,

  BENJAMIN SECURITIES, INC.

  By:
  /s/ Michael Coyne

  Name:
  Michael Coyne

  Title:
  Principal

[Signature
Page to Underwriters’ Acceleration Request Letter]