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    1-844-9 AURORA

    info@auroramj.com

    AURORAMJ.COM

    10355 Jasper Avenue, Suite 500

    Edmonton, AB, Canada

    T5J 1Y6

March 27, 2020

Filed via EDGAR

Securities and Exchange Commission

Washington, D.C. 20549

RE:  Aurora Cannabis
Inc. (the “Issuer”, the “Company”, “Aurora”)

Form 40-F for the
Fiscal Year Ended June 30, 2019

Filed September 11,
2019

File No. 001-38691

We are writing in response to your letter
dated March 13, 2020 with respect to your review of our disclosure record. Our responses are noted below, using the same numbering
as set out in your letter.

Comment #1 – Report of Independent
Registered Public Accounting Firm

On March 27, 2020, we filed
Form 40-F/A which includes the following documents as Exhibits 99.9 and 99.10, respectively, to the Amended Annual Report:

(a) the audit report of
MNP LLP, the Company’s former independent registered public accounting firm, dated September 24, 2018, in respect of the
Company’s audited consolidated statements and the notes thereto as at and for the years ended June 30, 2018 and June 30,
2017; and

(b) the consent of MNP LLP.

Comment #2 – Segmented Information

 (i) The primary business activity of the Issuer is the production and sale of cannabis and cannabis
derivative products and this represents the Issuer’s Cannabis operating segment. The Cannabis operating segment is comprised
of eight cash generating units (‘CGU’s) which support the production of cannabis and cannabis derivative products.
The Issuer’s Horizontally Integrated Business is a non-material cash-generating unit which produces and sells indoor cultivator
products. The following table outlines the cash generating units that comprise both of the Issuer’s operating segments:

    Cannabis Operating Segment

    Cash Generating Unit
    Primary Business Activities
    % of Consolidated Revenue

    Canadian Cannabis CGU
    Cultivation and sale of cannabis products within Canada.
    86%

    Cannabis European Union CGU
    Purchase and sale of cannabis products within  Europe.
    6%

    Latin American CGU
    Cultivation and sale of cannabis and hemp products within Latin America.
    <1%

    European Hemp CGU
    Cultivation and sale of hemp products within Europe.
    2%

    Canadian Hemp CGU
    Cultivation and sale of hemp products within Canada.
    1%

    Analytical Testing CGU
    Analytical and quality control testing of cannabis and cannabis related products for Aurora’s Canadian Cannabis CGU as well as external third- party licensed producers.
    1%

    Patient Counselling CGU
    Operations dedicated to patient counseling and educational operations to support patients of the Canadian Cannabis CGU.
    2%

    Design, Engineering and Construction CGU
    Operations dedicated to consulting, engineering and design services to support the construction of the Issuer’s cannabis production facilities.
    1%

    Horizontally Integrated Businesses

    Production and sale of indoor cultivators
    Production and sale of indoor cultivator products.
    1%

The Issuer does not aggregate operating
segments. The Issuer has two operating segments each which is considered its own reportable segment. The majority of the Issuer’s
consolidated net revenues are generated through the Canadian Cannabis CGU and to a lesser extent the Cannabis European CGU. The
Issuer currently exports medical cannabis from the Canadian Cannabis CGU to the Cannabis European CGU for re-sale into the European
market and decisions to export are primarily based on product availability while continuing to meet Canadian demand requirements.

The Issuer’s Chief Operating
Decision Makers (“CODMs”) are the Chief Executive Officer, Chief Financial Officer and Chief Operational Officer. The
CODMs utilize an internal consolidated budget and forecast (“the Corporate Model”) to assess actual financial results/performance
of the Company, allocate resources and make operating decisions. The Corporate Model consolidates discrete information of the cash
generating units which support and form part of the Cannabis operating segment. The Corporate Model, which is updated and reviewed
at least quarterly, includes the following information:

o
  Kilograms produced by production facility

o
 Kilograms allocated to each sales channel (domestic, international, medical, consumer, bulk sales)

o
 Average selling price by product (dried cannabis, oils, pre-rolls/cannabis derivatives) and total consolidated average selling
price

o
  Revenues by product (dried cannabis, cannabis derivatives);

o
  Excise taxes by product;

o
  Production (COGS) and SG&A costs on a consolidated basis; and

o
  Capital Expenditures on a consolidated basis.

Although the Issuer provides
disaggregated information in the 2019 MD&A such as by sales channel (medical, consumer, wholesale bulk) and product (dried
cannabis and cannabis extracts), these groups are not considered to be separate operating segments of the Issuer. Factors supporting
this conclusion include:

 (a) CODMs do not make resource allocation decisions based on the quarterly MD&A filings.

 (b) As the Company’s cannabis strains can interchangeably be produced or undergo further processing
at any of Aurora’s facilities and are not designated for any specific sales channel (most strains can be sold in either channel
to meet demand), sales channel was not determined to be a separate operating segment. The main driver of resource allocation is
currently rationing of production capacity to meet future demand. The designation of sales channel is secondary to meeting the
Company’s overall production targets and although pricing may differ between sales channels, CODM’s still review the
Issuer’s performance on a gross revenue/production basis and;

 (c) The Company’s current financial systems do not track discrete financial information for cost
of goods sold and selling, general and administrative expenses by sales channel or product. The bifurcation and determination of
cost of sales by sales channel and product is performed quarterly for MD&A disclosures. This is based on the weighted average
cost per unit for the operating segment as a whole which is then allocated to sales channels based on units sold.

 (d) CODMs only receive revenue information by sales channel; as the Company’s revenues are generated
primarily through the sale of cannabis and cannabis derivative products which vary in profitability driven by different variable
cost profiles, the CODM does not consider revenue information alone a sufficient measure of profitability to make resource allocation
decisions;

The Issuer notes that its Cannabis
operations includes vertically integrated businesses for which the CODMs assess the operating performance and allocates financial
resources based on future consolidated production/revenue demand for cannabis related products. This aggregated information drives
the level of construction activities (i.e. Design, Engineering and Construction CGU), cultivation and distribution requirements
(i.e. Canadian Cannabis CGU, Cannabis European Union CGU, Latin American CGU, European Hemp CGU, and Canadian Hemp CGU), product
testing and R&D (i.e. Analytical Testing CGU) and customer engagement (i.e. Patient Counselling CGU). The information required
for resource allocation/performance assessment for all subsidiaries is included within the Corporate model. CODMs review the performance
and impact of vertically integrated operations at a consolidated level rather than at the specific function or entity level given
(i) the overall materiality to consolidated operations and (ii) that their activities support the overall production of cannabis
and cannabis derivative products.

The CODMs also review separate
discrete financial information of the Production and sale of indoor cultivator CGU. These reports include revenues, costing, income/loss
and cash requirements for the business unit. The indoor cultivator CGU serves different markets, production processes and is therefore
assessed as a separate business unit from the Cannabis operating segment. The Horizontally Integrated Business operating segment
has become immaterial to the Issuer’s overall business, however, segregated disclosure remains given the distinct nature
of products sold and customers served.

Please refer to “Appendix
A” for a chart of the Issuer’s management structure.

 (ii) The Issuer’s Corporate caption primarily includes financial instruments due to its centralized
Treasury function, such as cash, short term investments, derivatives, marketable securities, investments in associates and debt.
A significant portion of the Corporate caption’s net (loss)/income is driven by the Issuer’s fair value accounting
of its derivatives, gain on disposal of investment in associates and impairment recognized on its investment in associates. The
Issuer’s Corporate caption also includes centralized expenditures such as corporate insurance, audit fees, regulatory fees,
share based compensation and financing expenditures related to the Issuer’s debt. The Issuer does not allocate the cost or
impact of these corporate activities to its reportable segments given that they pertain to discrete activities which are not directly
related to underlying operations of the reportable segments.

We trust the foregoing to be in order. Should
you have any questions or require additional information, please contact the undersigned.

Yours truly,

AURORA CANNABIS INC.

/s/ Jillian Swainson

    Per:
    JILLIAN SWAINSON

    Chief Legal Officer and

    Corporate Secretary

Appendix A

See attached “Appendix A
- SEC Response – FINAL”