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                             April 28, 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. 2 to
Draft Registration Statement on Form S-1
                                                            Submitted April 20,
2021
                                                            CIK No. 0001617765

       Dear Mr. Cross:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our April
14, 2021 letter.

       Amendment No. 2 to Draft Registration Statement on Form S-1

       Use of Proceeds, page 54

   1.                                                   We note your response
to prior comment 3. If still true, please expand to disclose that
                                                        you do not currently
have any businesses targeted for acquisitions.
       Signatures, page II-7

   2.                                                   We note your response
to prior comment 6. Instruction 1 to Signatures on Form S-1
                                                        requires, in relevant
part, that the registration statement shall be signed by the
                                                        company's controller or
principal accounting officer. If the person who performs the
 Leslie Cross
Salona Global Medical Device Corporation
April 28, 2021
Page 2
      functions of your principal accounting officer has signature line on the
registration
      statement, please revise the corresponding parenthetical descriptor under
the Title column
      to indicate that such person is, or also is, signing in the capacity of
your principal
      accounting officer.
       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 28, 2021 Page 2
cc:       Richard Raymer, Esq.
FirstName LastName