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   Helius Medical Technologies, Inc.: Correspondence - Filed by newsfilecorp.com

Helius
Medical Technologies, Inc.

Suite 400, 41 University Drive

Newtown, PA 18940

July 11, 2016

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    100 F. Street, N.E.

    Washington, D.C. 20549-3561

    Re:
    Helius Medical Technologies, Inc.

    Registration Statement on Form S-1 (File No.
      333-211129)

    Acceleration Request

    Requested Date: July 12, 2016

    Requested Time: 4:30 p.m. Eastern Daylight
      Time

Ladies and Gentlemen:

     Pursuant to Rule 461 of
Regulation C promulgated under the Securities Act of 1933, as amended, Helius
Medical Technologies, Inc. (the “Company”) hereby requests that the
above-referenced registration statement on Form S-1, as amended (the “Registration
Statement”) be accelerated so that the same may be declared effective at the
“Requested Date” and “Requested Time” set forth above, or as soon thereafter as
practicable.

     In connection with this acceleration
request, the Company hereby acknowledges that:

  should the U.S. Securities and Exchange Commission (the “Commission”) or
  the staff, acting pursuant to delegated authority, declare the filing
  effective, it does not foreclose the Commission from taking any action with
  respect to the filing;

  the action of the Commission or the staff, acting pursuant to delegated
  authority, in declaring the filing effective, does not relieve the Company
  from its full responsibility for the adequacy of the disclosure in the filing;
  and

  the Company may not assert staff comments and the declaration of
  effectiveness as a defense in any proceeding initiated by the Commission or
  any person under the federal securities laws of the United States.

     The Company understands that the
staff will consider this request as confirmation by the Company of its awareness
of its responsibilities under the Securities Act of 1933 and the Securities
Exchange Act of 1934 as they relate to the proposed public offering of the
securities specified in the Registration Statement.

     The Company requests that the staff notify us of the
effectiveness of the Registration Statement by telephone call to Ori Solomon of
Proskauer Rose LLP at (617) 526-9889. Please also provide a copy of the
Commission’s order declaring the Registration Statement effective to Mr. Solomon via e-mail at osolomon@proskauer.com and via mail
at Proskauer Rose LLP, One International Place, Boston, Massachusetts, 02110.

[SIGNATURE PAGE FOLLOWS]

    Respectfully submitted,

    HELIUS MEDICAL TECHNOLOGIES, INC.

    By: /s/
      Joyce LaViscount

    Joyce LaViscount

    Chief Financial Officer and Chief Operating

    Officer

    cc:

      Ori Solomon, Esq.
(Proskauer Rose
  LLP)

[Signature Page to Acceleration Request]