United States securities and exchange commission logo October 19, 2021 Craig Shesky Chief Financial Officer TMC the metals Co Inc. 595 Howe Street, 10th Floor Vancouver, British Columbia V6C 2T5 Re: TMC the metals Co Inc. Registration Statement on Form S-1 Filed October 7, 2021 File No. 333-260126 Dear Mr. Shesky: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Kevin Dougherty at (202) 551-3271 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Jeffrey Schultz