United States securities and exchange commission logo June 21, 2022 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. Amendment No. 1 to Post-Effective Amendment No. 1 to Registration Statement on Form S-1 Filed May 31, 2022 File No. 333-260126 Dear Mr. Shesky: We have reviewed your amended registration statement and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Amendment No. 1 to Post-Effective Amendment No. 1 to Form S-1 General 1. We note that your filing incorporates by reference the consent of various experts from those consents provided with the initial S-1 filing, including that of counsel and of various "qualified persons" responsible for portions of your technical reports filed as Exhibit 96.1 and 96.2 on the NORI Property and TOML Mineral Resource, respectively. Considering that this post-effective amendment will have a new date of effectiveness, please revise to provide new consents from all such experts. See Item 601(b)(23) and Item 1302(b)(4)(iv) of Regulation S-K, as well as Securities Act Section 7(a), Securities Act Rule 436 and Securities Act Rule 439. Craig Shesky TMC the metals Co Inc. June 21, 2022 Page 2 Please contact Kevin Dougherty, Staff Attorney, at (202) 551-3271 or Loan Lauren Nguyen, Legal Branch Chief, at (202) 551-3642 with any other questions. Sincerely, FirstName LastNameCraig Shesky Division of Corporation Finance Comapany NameTMC the metals Co Inc. Office of Energy & Transportation June 21, 2022 Page 2 cc: Jeffrey Cohan FirstName LastName