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                             March 3, 2023

       Michael Munoz
       Chief Financial Officer
       Engine Gaming & Media, Inc.
       2110 Powers Ferry Road SE
       Suite 450
       Atlanta, GA 30339

                                                        Re: Engine Gaming &
Media, Inc.
                                                            Form 20-F for
Fiscal Year Ended August 31, 2022
                                                            File No. 001-39389

       Dear Michael Munoz:

             We have reviewed your filing and have the following comment. In
our comment, we
       may ask you to provide us with information so we may better understand
your disclosure.

              Please respond to this comment within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this comment, we may have additional comments.

       Form 20-F for Fiscal Year Ended August 31, 2022

       Independent Auditor's Report, page F-4

   1.                                                   Please advise your
independent auditor that their reports on pages F-4 and F-70 should
                                                        include a statement
that their audit was conducted in accordance with the standards of the
                                                        Public Company
Accounting Oversight Board (United States). Please refer to Instruction
                                                        2 to Item 8.A.2 of Form
20-F. Also, audit opinions using conditional language, like
                                                           may,    in
expressing a conclusion concerning the existence of substantial doubt about an
                                                        entity   s ability to
continue as a going concern are not appropriate. Please make
                                                        arrangements with your
auditor for their report to clearly state that there is substantial
                                                        doubt about your
ability to continue as a going concern, if true. Finally, their revised
                                                        reports should meet the
requirements of PCAOB Auditing Standards 2415 and 3101.
                                                         Please include the
revised reports in an amended Form 20-F.
 Michael Munoz
Engine Gaming & Media, Inc.
March 3, 2023
Page 2

        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.

       You may contact Angela Lumley at 202-551-3398 or Rufus Decker at
202-551-3769 with
any questions.



FirstName LastNameMichael Munoz                           Sincerely,
Comapany NameEngine Gaming & Media, Inc.
                                                          Division of
Corporation Finance
March 3, 2023 Page 2                                      Office of Trade &
Services
FirstName LastName