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                             April 14, 2021

       Leslie Cross
       Interim Chief Executive Officer
       Salona Global Medical Device Corporation
       2800 Park Place
       666 Burrard Street
       Vancouver, British Columbia
       V6C 2Z7

                                                        Re: Salona Global
Medical Device Corporation
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted April 6,
2021
                                                            CIK No. 0001617765

       Dear Mr. Cross:

             We have reviewed your amended 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.

       Amendment No. 1 to Draft Registration Statement on Form S-1

       The Offering, page 9

   1.                                                   We note your response
to prior comment 2 and revised cover page disclosure. As
                                                        requested by our prior
comment, please also revise your disclosure here to clarify that
                                                        the common shares will
be offered by the selling shareholders at a price of C$0.4749 until
                                                        trading resumes on the
TSXV, as disclosed on the prospectus cover page.
 Leslie Cross
FirstName   LastNameLeslie  Cross
Salona Global   Medical Device Corporation
Comapany
April       NameSalona Global Medical Device Corporation
       14, 2021
April 214, 2021 Page 2
Page
FirstName LastName
Risk Factors
Our common shares are a high risk investment, page 10

2.       We note your response to prior comment 9 and the revision made on page
27 that "the
         Consideration Shares will not be available for sale into the market or
resale by the
         holders." We further note each Consideration Share may be converted
into one share
         common stock of the Company at the election of the holder. Please
revise to clarify if
         shares of your common stock representing converted shares of
Consideration Shares are
         available for sale into the market or resale by the holders thereof.
If so, please expand
         your risk factor disclosure to address the risks from the converted
Consideration Shares
         being sold into market and disclose how and when those shares would be
available for
         resale.
Use of Proceeds, page 55

3.       We note you will use the proceeds from the exercise of the Resulting
Issuer Warrants, as
         well as from the exercise of the Salona Compensation Options and
Exchangeable
         Compensation Option to acquire other medical device businesses after
the SDP
         transaction closes. Please expand your disclosure to identify, if
known, any such
         businesses targeted. Refer to Instruction 6 of Item 504 of Regulation
S-K for guidance.
Management's Discussion and Analysis of Financial Condition and Results of
Operations of
Salona Global Medical Device Corporation
Liquidity and Capital Resources, page 67

4.       We have read your revised disclosure in response to prior comment 18
from our letter
         dated March 29, 2021. Please revise your disclosure to provide a
discussion of changes in
         operating, investing and financing cash flows for each period
presented. Your revised
         discussion should not only quantify the impact of the line item(s)
which contributed most
         to the changes but should also provide detailed explanations of the
reasons for the
         fluctuations. Your revised discussion should also focus on the primary
drivers of and
         other material factors necessary to an understanding of your cash
flows and the indicative
         value of historical cash flows. See guidance in Section IV.B.1 of SEC
Release 33-8350
         and Item 303 of Regulation S-K.
Results of Operations of South Dakota Properties, page 68

5.       We have read your revised disclosure in response to prior comment 18
from our letter
         dated March 29, 2021. Your discussion of the results of operations for
South Dakota
         Partners does not address the underlying reasons for the decline in
revenue nor provide an
         analysis of the period-over-period fluctuations in the income
statement expense line
         items. Please revise to provide a full analysis of the operating
results for South Dakota
         Partners. Where a material change is attributed to two or more
factors, including any
         offsetting factors, the contribution of each identified factor should
be described in
         quantified terms. Refer to Item 303(A)(3) and Instruction 4 to Item
303(A) of Regulation
 Leslie Cross
Salona Global Medical Device Corporation
April 14, 2021
Page 3
       S-K and Section III.D of SEC Release No. 33-6835.
Signatures, page II-7

6.     We note your response to prior comment 22; however we do not see a
corresponding
       change in your amendment. Please revise to have your principal
accounting officer or
       controller sign the registration statement and indicate by parenthetical
indication who is
       signing in that capacity. Refer to Instruction 1 to Signatures on Form
S-1.
       You may contact Tracey McKoy at 202-551-3772 or Terence O'Brien at
202-551-3355 if
you have questions regarding comments on the financial statements and related
matters. Please
contact David Gessert at 202-551-2326 or Tim Buchmiller at 202-551-3635 with
any other
questions.



                                                             Sincerely,
FirstName LastNameLeslie Cross
                                                     Division of Corporation
Finance
Comapany NameSalona Global Medical Device Corporation
                                                     Office of Life Sciences
April 14, 2021 Page 3
cc:       Richard Raymer, Esq.
FirstName LastName