2108 N St., Suite 4254

Sacramento, California 95816

March 14, 2025

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549-3628

Attn: Benjamin Holt, Division of Corporation Finance, Office of Real Estate & Construction

Re:	DevvStream Corp. (the “Company”)
	Registration Statement on Form S-1
	File No. 333-285728
	Request for Acceleration

Dear Sir:

In accordance with Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, the undersigned respectfully requests that the effective date of the above referenced Registration Statement on Form S-1 be accelerated so that it will be declared effective at 4:30 p.m., Eastern Time, on March 14, 2025 or as soon thereafter as is practicable.

Once the Registration Statement has been declared effective, please confirm that event with our counsel, Julio Esquivel, of Shumaker, Loop & Kendrick, LLP, at (813) 227-2325.

Very truly yours,

By:	/s/David Goertz
	Name:	David Goertz
	Title:	Chief Financial Officer

cc: Julio C. Esquivel, Shumaker, Loop & Kendrick, LLP