SecProbe.io

November 2, 2018
Rick Pauls
Chief Executive Officer
DiaMedica Therapeutics Inc.
2 Carlson Parkway, Suite 260
Minneapolis, MN 55447
Re:DiaMedica Therapeutics Inc.
Amendment No. 2 to Draft Registration Statement on Form 10
Submitted October 19, 2018
CIK No. 0001401040
Dear Mr. Pauls:
            We have reviewed your amended draft registration statement and have the following
comment.
            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 comment applies 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 this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Amendment No. 2 to Draft Registration Statement on Form 10 submitted October 19, 2018
Item 1. Business
License Agreement, page 19
1.We note that pursuant to the license and collaboration agreement with Ahon Pharma, you
have the potential to receive high single to low double-digit royalties on net sales of
DM199 in the licensed territories.  Please revise the reference to "low double-digit" to
disclose a royalty within a ten percent range.

 FirstName LastNameRick Pauls
 Comapany NameDiaMedica Therapeutics Inc.
 November 2, 2018 Page 2
 FirstName LastName
Rick Pauls
DiaMedica Therapeutics Inc.
November 2, 2018
Page 2
            You may contact Franklin Wyman at 202-551-3660 or Angela Connell at 202-551-3426
if you have questions regarding comments on the financial statements and related
matters.  Please contact Irene Paik at 202-551-6553 or Mary Beth Breslin at 202-551-3625 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance
cc:       Amy E. Culbert, Esq.