June 13, 2019

Joseph Zirkman
Senior Vice President and General Counsel
DIRTT ENVIRONMENTAL SOLUTIONS LTD
7303 30 Street S.E.
Calgary, Alberta, Canada T2C 1N6

       Re: DIRTT ENVIRONMENTAL SOLUTIONS LTD
           Draft Registration Statement on Form 10, submitted May 14, 2019

Dear Mr. Zirkman:

       We have reviewed your draft registration statement and have the
following comments. In
some of our comments, we may ask you to provide us with information so we may
better
understand your disclosure.

       Please respond to this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form 10 submitted May 14, 2019

Properties, page 42

1.     Advise what consideration you have given to filing the lease agreements
for your principal
       executive offices and principal manufacturing facilities as exhibits to
the Form 10. See
       Item 15 of Form 10 and Item 601(b)(10) of Regulation S-K.
Description of securities to be registered
General, page 67

2.     Disclose whether holders of common stock are entitled to cumulative
voting rights in the
       election of directors.
Revenue Recognition, page F-11

3.     You state you recognize revenue upon transfer of control to the
customer, which typically
 Joseph Zirkman
FirstName LastNameJoseph Zirkman
DIRTT ENVIRONMENTAL SOLUTIONS LTD
Comapany NameDIRTT ENVIRONMENTAL SOLUTIONS LTD
June 13, 2019
June 13, 2019 Page 2
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FirstName LastName
         occurs upon shipment. Please clarify whether your reference to "the
customer" means
         a distribution partner or end-user customer. Also, tell us how you
determine when the
         customer has obtained control. Refer to 606-10-25-30.
4.       Please clarify whether your ICE license revenue that is not considered
distinct and is
         recognized in conjunction with product sales is different than the ICE
Software revenue
         that is recognized over the license period. If they are different
please further elaborate on
         the nature of each revenue stream and how you evaluated each promise
in accordance
         with ASC 606-10-25-14 through ASC 606-10-25-19.
5.       We note your statement that your customer arrangements do not produce
contract assets or
         liabilities that are material to your consolidated financial
statements. On page F-12, you
         state that customer deposits received are recognized as a liability on
the balance sheet
         until the revenue recognition criteria is met. You further state that
you recognize an
         unbilled receivable when revenue is recognized prior to invoicing.
Finally, Note 14
         includes contract liabilities for both periods presented. Given the
significant increase
         between the periods presented and the expected continued growth in the
business, please
         reconcile this apparent discrepancy in your disclosures and tell us
your consideration of
         the disclosure requirements in ASC 606-10-50-8 through 50-10.
6.       We note your disclosure on page F-12 that in certain instances you
facilitate contracting of
         certain sales on behalf of distribution partners for which in some
instances you recognize
         revenue on a gross basis and in other instances you recognize revenue
on a net basis.
         Please clarify the nature of the goods and services for which you
recognize revenue on a
         gross basis and those for which you recognize revenue on a net basis
and tell us how such
         arrangements differ from your typical arrangements with your
distributors. In providing
         your response, please also tell us how you determined whether you
controlled such goods
         and services prior to transfer in determining whether you are acting
as a principal or agent
         in such arrangements. Please refer to ASC 606-10-55-36 through 55-40.
Please also tell us
         how much of your total consolidated revenue for each of the periods
presented related to
         such arrangements including how much was recognized on a gross basis
versus a net
         basis.


        You may contact Ameen Hamady, Staff Accountant at 202-551-3891or
Terence
O'Brien, Accounting Branch Chief at 202-551-3355 if you have questions
regarding comments
on the financial statements and related matters. Please contact Edward Kelly,
Senior Counsel at
202-551-3728 or Amanda Ravitz, Assistant Director at 202-551-3412 with any
other questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
 Joseph Zirkman
DIRTT ENVIRONMENTAL SOLUTIONS LTD
June 13, 2019
FirstName LastNameJoseph Zirkman
Page 3
Comapany NameDIRTT ENVIRONMENTAL SOLUTIONS LTD
                                         Office of Manufacturing and
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FirstName LastName