United States securities and exchange commission logo July 15, 2022 Dane C. Andreeff Chief Executive Officer HELIUS MEDICAL TECHNOLOGIES, INC. 642 Newtown Yardley Road, Suite 100 Newtown, PA 18940 Re: HELIUS MEDICAL TECHNOLOGIES, INC. Registration Statement on Form S-1 Filed July 13, 2022 File No. 333-266107 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 Christine Westbrook at 202-551-5019 with any questions. Sincerely, Division of Corporation Finance Office of Life Sciences cc: Emily Johns, Esq.