December 20, 2024

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.
           Form 10-K for Fiscal Year Ended December 31, 2023
           Filed March 25, 2024
           File No. 001-39281
Dear Craig Shesky:

       We have reviewed your filing and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2023
Risk Factors
Our ability to generate revenue will be diminished if we are unable to compete
with
substitutions for the minerals..., page 56

1.     We note your graphic on page 11 of the evolution of cathode chemistry
across
       passenger EVs, which discloses LFP batteries growing their market share
from 4% in
       2015 to 42% in 2023. Accordingly, please revise this risk factor to
disclose not just
       that "if these industries shift to new technologies or products (e.g.,
nickel-rich battery
       chemistries could be replaced by other battery chemistries that do not
use nickel or
       cobalt such as lithium iron phosphate (LFP)...)...it could result in a
decline in demand
       for our metal products"; but to also disclose the present increase in
usage of LFP
       battery chemistry in EVs and any impact on the demand for your proposed
products.
        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.
 December 20, 2024
Page 2

       Please contact Joanna Lam at 202-551-3476 or Craig Arakawa at
202-551-3650 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Kevin Dougherty at 202-551-3271 or Daniel Morris at 202-551-3314 with
any other
questions.



                                                        Sincerely,

                                                        Division of Corporation
Finance
                                                        Office of Energy &
Transportation
cc:   Daniel Kajunski