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            September 10, 2021

       Dane Andreeff
       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 September 3,
2021
                                                            File No. 333-259334

       Dear Dane 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 Michael Davis at 202-551-4385 or Laura Crotty at
202-551-7614 with any
       questions.




            Sincerely,


            Division of Corporation Finance

            Office of Life Sciences
       cc:                                              Phillip D. Torrence