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February 17, 2023
Dennis Nelson
Chief Financial Officer
Salona Global Medical Device Corporation
6160 Innovation Way
Carlsbad, California 92009
Re:Salona Global Medical Device Corporation
Form 10-K for the Fiscal Year Ended February 28, 2022
Filed May 31, 2022
Form 10-Q for the Quarterly Period Ended November 30, 2022
Filed January 17, 2023
File No. 333-255642
Dear Dennis Nelson:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended February 28, 2022
Management's Discussion and Analysis and Results of Operations
Non-GAAP Measures, page 30
1.The table on page 30 appears to give more prominence to the non-GAAP Adjusted
EBITDA measure over the GAAP net loss since you only include the non-GAAP
measure. Please revise future filings to include your GAAP net loss in that table or revise
to remove Adjusted EBITDA.  Refer to Item 10(e)(1)(i) of Regulation S-K and Question
102.10 of the Non-GAAP Financial Measures Compliance and Disclosure
Interpretations Updated December 13, 2022.
2.We note that you have excluded transaction costs including legal, financial, audit and US
& Canadian regulatory expenses in Adjusted EBITDA.  Please quantify the amounts

 FirstName LastNameDennis  Nelson
 Comapany NameSalona Global Medical Device Corporation
 February 17, 2023 Page 2
 FirstName LastNameDennis  Nelson
Salona Global Medical Device Corporation
February 17, 2023
Page 2
included in these transaction costs and explain to us how the exclusion of these costs is
consistent with the guidance in Question 100.01 of the Non-GAAP Financial Measures
Compliance and Disclosure Interpretations Updated December 13, 2022.
Financial Statements
Consolidated Statement of Operations and Comprehensive Loss, page F-3
3.Please explain to us how the presentation of net (loss) income before the undernoted and
amortization of intangible assets, depreciation of property and equipment, amortization of
right-of-use assets, transaction costs and regulatory expenses, and provision for
impairment included below operating expenses is consistent with the guidance in Article
8  of Regulation S-X and SAB Topic 11B, which indicates that depreciation and
amortization should not be positioned in the income statement in a manner which results
in reporting a figure for income before depreciation.  In addition, this presentation appears
to result in a non-GAAP measure that is based on individually tailored accounting
principles as it does not contemplate all operating expenses. Refer to the
requirements guidance in Question 100.04 of the Non-GAAP Financial Measures
Compliance and Disclosure Interpretations Updated December 13, 2022.
Note 4. Acquisitions
Assets Acquired from ALG-Health, LLC, page F-18
4.We see from your disclosure that you completed an asset acquisition of certain assets from
ALG for up to a maximum of 21 million nonvoting Class A shares of the company subject
to the achievement of certain revenue and EBITDA targets. Further, we see that ALG has
yet to earn the right to exchange any of its non-voting shares in ALG Health Plus for
nonvoting Class A shares of the company and as a result, no purchase price has been
allocated to these assets. Provide us with your calculation of the purchase price for the
ALG assets and tell us how you recorded the acquisition of these assets at closing.
Simbex LLC Purchase Price, page F-18
5.We see that the total purchase price for Simbex was approx. $12.5 million. Please
provide us with your consideration of the requirements of Rule 3-05 of Regulation S-X for
the acquisition, including your calculation of the significance tests as set forth under Rule
1-02(w).
6.In this regard, we note your disclosure that Simbex generated over $8,000,000 in audited
revenues in 2020 with reported gross margins of 50% and was cash flow positive. We
noted similar unaudited information related to the Mio-Guard acquisition as well. Please
tell us why you believe that disclosure of unaudited information is appropriate or remove
it in future filings.

 FirstName LastNameDennis  Nelson
 Comapany NameSalona Global Medical Device Corporation
 February 17, 2023 Page 3
 FirstName LastNameDennis  Nelson
Salona Global Medical Device Corporation
February 17, 2023
Page 3
Form 10-Q for the Quarterly Period Ended November 30, 2022
Note 4. Acquisitions
Mio-Guard LLC, page 20
7.We see your disclosure that the acquisition of Mio-Guard was comprised of $589,340 of
cash and Salona stock at closing, and on future periods on an earnout basis, however the
tabular calculation of the purchase price that follows does not appear to include the cash
payment. Please advise.
8.Please provide us with your consideration of the requirements of Rule 3-05 of Regulation
S-X for the DaMar acquisition, including your calculation of the significance tests as set
forth under Rule 1-02(w).
Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 37
9.Please revise future filings to provide a more comprehensive and quantified discussion
and analysis of your results of operations, including the factors that impacted your results
between comparative periods. You should also discuss how much of the increase in
revenues was from acquisitions or changes in volume, selling prices or product mix. Refer
to the requirements of Item 303(b)(2) of Regulation S-K.
Item 4. Controls and Procedures
Evaluation of Disclosure Controls and Procedures, page 40
10.We note that Disclosure Controls and Procedures and Internal Control over Financial
Reporting were effective in your February 28, 2022 Form 10-K.  However, you indicate in
this filing that you concluded as of November 30, 2022, the Company’s disclosure
controls and procedures were not effective. We also note your disclosure that there have
not been any changes to internal control over financial reporting.  Please explain to us
why you concluded that controls and procedures were not effective as of November 30,
2022, including providing details of any material weaknesses that were identified in your
assessment.
            In closing, 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.

 FirstName LastNameDennis  Nelson
 Comapany NameSalona Global Medical Device Corporation
 February 17, 2023 Page 4
 FirstName LastName
Dennis  Nelson
Salona Global Medical Device Corporation
February 17, 2023
Page 4

            You may contact Julie Sherman at (202) 551-3640 or Brian Cascio, Accounting Branch
Chief, at (202) 551-3676 with any questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services