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                                                            January 14, 2025

Fareed Aljawhari
Chief Executive Officer
Micropolis Holding Company
Warehouse 1, Dar Alkhaleej Building
Dubai Production City, Dubai, UAE

       Re: Micropolis Holding Company
           Amendment No. 5 to Registration Statement on Form F-1
           Filed January 10, 2025
           File No. 333-276231
Dear Fareed Aljawhari:

     We have reviewed your amended 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.

Amendment No. 5 to Registration Statement on Form F-1 filed January 10, 2025
General

1.     Please update your compensation disclosure to reflect the fiscal year
ended December
       31, 2024.
 January 14, 2025
Page 2

       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
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