SecProbe.io

CORRESP
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May 2, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, NE

Washington, D.C. 20549

    Re:
    Helius Medical Technologies, Inc.

    Registration Statement on Form S-1, as amended

    File No. 333-278698

    Withdrawal of Acceleration Request

Ladies and Gentlemen:

Reference is made to our letter
filed as correspondence with the U.S. Securities and Exchange Commission via EDGAR on May 1, 2024 (the “Acceleration Request”),
in which we requested the acceleration of the effective date of the above-referenced Registration Statement on Form S-1, as amended
(File No. 333-278698) (the “Registration Statement”) for 4:05 p.m., Eastern Time, on May 2, 2024, or as soon
thereafter as practicable, in accordance with Rule 461 under the Securities Act of 1933, as amended. We are no longer requesting
that such Registration Statement be declared effective at such date and time and we hereby formally withdraw our request for acceleration
of the effective date.

Please direct any questions with respect to the
withdrawal of the Acceleration Request of the Registration Statement to Emily Johns of Honigman LLP, counsel to the Company, by telephone
at (616) 649-1908 or, in her absence, Lauren Legner of Honigman LLP by telephone at (313) 465-7119.

[Signature page follows]

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    Sincerely,

    Helius Medical Technologies, Inc.

    By:
    /s/ Dane C. Andreeff                     

    Dane C. Andreeff

    President and Chief Executive Officer

    cc:
    Emily Johns, Honigman LLP

    Lauren Legner, Honigman LLP