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                          December 2, 2020

       Dane Andreeff
       Interim President and Chief Executive Officer
       Helius Medical Technologies, Inc.
       642 Newtown Yardley Road, Suite 100
       Newtown, Pennsylvania 18940

                                                        Re: Helius Medical
Technologies, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed November 25,
2020
                                                            File No. 333-250974

       Dear Mr. Andreeff:

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. 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.

                                                        Please contact Courtney
Lindsay at (202) 551-7237 with any questions.




                          Sincerely,


                          Division of Corporation Finance

                          Office of Life Sciences