April 2, 2025

Sunny Trinh
Chief Executive Officer
DevvStream Corp.
2108 N St., Suite 4254
Sacramento, CA 95816

       Re: DevvStream Corp.
           Registration Statement on Form S-1
           Filed March 25, 2025
           File No. 333-286070
Dear Sunny Trinh:

        Our initial review of your registration statement indicates that it
fails in numerous
material respects to comply with the requirements of the Securities Act of
1933, the rules and
regulations thereunder and the requirements of the form. More specifically, it
appears
that the financial statements in your registration statement do not comply with
the
updating requirements of Rule 8-08 of Regulation S-X.

       We will provide more detailed comments relating to your registration
statement
following our review of a substantive amendment that addresses these
deficiencies.

       Please contact Pearlyne Paulemon at 202-551-8714 with any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Real
Estate & Construction
cc:   Julio C. Esquivel