SecProbe.io

CORRESP
 1
 filename1.htm

 ELECTRA BATTERY MATERIALS CORPORATION

 133 Richmond Street W, Suite 602

 Toronto, Ontario

 M5H 2L3 Canada

 VIA EDGAR

 December 9, 2025

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Electra Battery Materials Corporation

 Registration Statement on Form F-3 (File No. 333-288364)

 Request for Acceleration of Effective Date

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended, Electra Battery Materials Corporation (the "Company") hereby requests that the Securities and Exchange Commission (the "Commission") accelerate the effective date of the above-referenced Registration Statement on Form F-3 (the "Registration Statement") so that the Registration Statement will be declared effective as of 4:30 p.m. Eastern time, on December 11, 2025, or as soon as practicable thereafter. The Company hereby authorizes Lisa R. Reidy or Thomas M. Rose, both of whom are attorneys at the Company's outside legal counsel, Troutman Pepper Locke LLP, to orally modify or withdraw this request for acceleration.

 Once the Registration Statement has been declared effective, please orally confirm that event with Ms. Reidy at (757) 932-9229 or Mr. Rose at (757) 687-7715.

 Thank you for your assistance in this matter.

 Sincerely,

 Electra Battery Materials Corporation

 /s/ Marty Rendall

 Name:
 Marty Rendall

 Title:
 Chief Financial Officer

 cc (via email):

 Trent Mell, President and Chief Executive Officer, Electra Battery Materials Corporation
 Thomas M. Rose, Troutman Pepper Locke LLP
 Lisa R. Reidy, Troutman Pepper Locke LLP

CORRESP
 1
 filename1.htm

 ELECTRA BATTERY MATERIALS CORPORATION

 133 Richmond Street W, Suite 602

 Toronto, Ontario

 M5H 2L3 Canada

 VIA EDGAR

 December 4, 2025

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Re:
 Electra Battery Materials Corporation

 Registration Statement on Form F-3 (File No. 333-291766)

 Request for Acceleration of Effective Date

 Ladies and Gentlemen:

 Pursuant to Rule 461 under the Securities Act of 1933, as amended, Electra Battery Materials Corporation (the "Company") hereby requests that the Securities and Exchange Commission (the "Commission") accelerate the effective date of the above-referenced Registration Statement on Form F-3 (the "Registration Statement") so that the Registration Statement will be declared effective as of 4:30 p.m. Eastern time, on December 8, 2025, or as soon as practicable thereafter. The Company hereby authorizes Lisa R. Reidy or Thomas M. Rose, both of whom are attorneys at the Company's outside legal counsel, Troutman Pepper Locke LLP, to orally modify or withdraw this request for acceleration.

 Once the Registration Statement has been declared effective, please orally confirm that event with Ms. Reidy at (757) 932-9229 or Mr. Rose at (757) 687-7715.

 Thank you for your assistance in this matter.

 Sincerely,

 Electra Battery Materials Corporation

 /s/ Marty Rendall

 Name:
 Marty Rendall

 Title:
 Chief Financial Officer

 cc (via email):

 Trent Mell, President and Chief Executive Officer, Electra Battery Materials Corporation
 Thomas M. Rose, Troutman Pepper Locke LLP
 Lisa R. Reidy, Troutman Pepper Locke LLP

CORRESP
 1
 filename1.htm

 Electra Battery Materials Corporation

 133 Richmond Street West, Suite 602

 Toronto, ON M5H 2L3

 Canada

 https://www.electrabmc.com/

 September 24, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 100 F. Street, N.E.

 Washington, D.C. 20549

 Attention: Michael Purcell and Laura Nicholson

 Re:

 Electra Battery Materials Corporation

 Amendment No. 2 to Registration Statement on Form F-3

 Filed August 11, 2025

 File No. 333-288364

 Ladies and Gentlemen:

 I am submitting this letter on behalf of Electra Battery Materials Corporation
(the " Company "), in response to the written comments of the staff (the " Staff ") of the U.S. Securities
and Exchange Commission (the " SEC "), contained in the Staff's letter, dated August 18, 2025 (the " Comment
Letter "), in connection with the Company's Registration Statement on Form F-3, filed with the SEC on June 27, 2025 (the
" Original Filing "), as amended on July 28, 2025 (" Amendment No. 1 ") and as further amended on August
11, 2025 (" Amendment No. 2 ").

 In response to the comments set forth in the Comment Letter, the Company
has further revised the Form F-3 as described below and is filing an amendment to the Form F-3 (" Amendment No. 3 ",
and together with the Original Filing, Amendment No. 1, and Amendment No. 2, the " Form F-3 ") with this response letter.

 For your convenience, the Company's responses are set forth below,
with the headings and numbered items of this letter corresponding to the headings and numbered items contained in the Comment Letter.
Each of the comments from the Comment Letter is restated in bold and italics prior to the Company's response.

 Amendment No. 2 to Registration Statement on Form F-3

 General

 1. We note your statement in your revised explanatory note that "[t]his Amendment No. 2 does
not reflect events occurring after the filing of the Original Filing" on June 27, 2025 and "does not modify or update the
disclosure therein in any way except as described above." Please remove such statement from your explanatory note and update your
prospectus disclosure accordingly. Refer to Form F-3.

 In response to the Staff's comment, the explanatory note
and the disclosure in the Form F-3 has been revised and updated in accordance with Form F-3.

 Securities and Exchange Commission

 September 24, 2025

 Page 2

 Exhibits

 2. We note that on August 15, 2025 you provided in a report on Form 6-K your interim financial statements
for the six months ended June 30, 2025. Please revise your registration statement to provide such interim financial information in your
prospectus, or to incorporate such interim financial information by reference. Refer to Item 5(b)(2) of Form F-3 and Item 8.A.5 of Form
20-F. Refer also to Item 6(c) of Form F-3.

 In response to the Staff's comment, we have incorporated
by reference into the Form F-3 the interim financial statements, as amended, of the Company for the three and six months ended June 30,
2025 and the related management's discussions and analysis, and have updated certain disclosures in the prospectus to reflected
such updated interim financial information.

 * * *

 We thank you for your prompt attention to this letter responding
to the Staff's Comment Letter and look forward to hearing from you at your earliest convenience. Please direct any questions concerning
this filing to the undersigned at (226) 979- 6699 or tmell@electrabmc.com.

 Sincerely,

 /s/ Trent Mell

 Chief Executive Officer

 Electra Battery Materials Corporation

 cc:

 Via Email

 Thomas M. Rose, Troutman Pepper Locke LLP

 Shona C. Smith, Troutman Pepper Locke LLP

August 18, 2025
Trent Mell
Chief Executive Officer
Electra Battery Materials Corporation
133 Richmond Street W, Suite 602
Toronto, ON M5H 2L3
Canada
Re:Electra Battery Materials Corporation
Amendment No. 2 to Registration Statement on Form F-3
Filed August 11, 2025
File No. 333-288364
Dear Trent Mell:
            We have reviewed your amended registration statement and have the following
comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our August 6, 2025 letter.
Amendment No. 2 to Registration Statement on Form F-3
General
1.We note your statement in your revised explanatory note that “[t]his Amendment No.
2 does not reflect events occurring after the filing of the Original Filing” on June 27,
2025 and “does not modify or update the disclosure therein in any way except as
described above.” Please remove such statement from your explanatory note and
update your prospectus disclosure accordingly. Refer to Form F-3.

August 18, 2025
Page 2
2.We note that on August 15, 2025 you provided in a report on Form 6-K your interim
financial statements for the six months ended June 30, 2025. Please revise your
registration statement to provide such interim financial information in your
prospectus, or to incorporate such interim financial information by reference. Refer to
Item 5(b)(2) of Form F-3 and Item 8.A.5 of Form 20-F. Refer also to Item 6(c) of
Form F-3.
            Please contact Michael Purcell at 202-551-5351 or Laura Nicholson at 202-551-3584
with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Thomas Rose

CORRESP
 1
 filename1.htm

 Electra Battery Materials Corporation

 133 Richmond Street West, Suite 602

 Toronto, ON M5H 2L3

 Canada

 https://www.electrabmc.com/

 August 11, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 100 F. Street, N.E.

 Washington, D.C. 20549

 Attention: Michael Purcell and Laura Nicholson

 Re:

 Electra Battery Materials Corporation
 Amendment No. 1 to Registration Statement on Form F-3
 Filed July 28, 2025
 File No. 333-288364

 Ladies and Gentlemen:

 I am submitting this letter on behalf of Electra Battery Materials Corporation
(the “ Company ”), in response to the verbal and written comments of the staff (the “ Staff ”) of the
U.S. Securities and Exchange Commission (the “ SEC ”), contained in the Staff’s letter, dated August 6, 2025 (the
“ Comment Letter ”), in connection with the Company’s Amendment No. 1 to Registration Statement on Form F-3, filed
with the SEC on July 28, 2025 (the “ Amendment No. 1 ”).

 In response to the comments set forth in the Comment Letter and the Staff’s
verbal comment, the Company has further revised its Registration Statement on Form F-3, originally filed with the SEC on June 27, 2025
and as amended by Amendment No. 1. As further described below, the Company is filing this second amendment to the Form F-3 (“ Amendment
No. 2 ”) with this response letter.

 For your convenience, the Company’s responses are set forth below,
with the headings and numbered items of this letter corresponding to the headings and numbered items contained in the Comment Letter and
the Staff’s verbal comment. Each of the comments is restated in bold and italics prior to the Company’s response.

 Amendment No. 1 to Registration Statement on Form F-3

 Exhibits

 1. We note the opinion filed as Exhibit 5.2 regarding the legality of the common shares that may be
issued pursuant to the "at the market" offering prospectus supplement. Please obtain and file a revised legality opinion
to ensure that the opinion does not contain assumptions that are overly broad, that “assume away” the relevant issue, or that
assume any of the material facts underlying the opinion or any readily ascertainable facts. Refer to Staff Legal Bulletin 19 at Sections
II.B.2.a. and II.B.3.a.

 In response to the Staff’s comment, Amendment No. 2 revises
the Form F-3 to include a revised Exhibit 5.2.

 Securities and Exchange Commission

 August 11, 2025

 Page
2

 Verbal Comment

 Documents Incorporated By Reference, page 4; Incorporation of Certain
Documents by Reference, page S-23

 2. Please include hyperlinks in the Form F-3 directing to the SEC filing for the filings listed under
the headings “Documents Incorporated by Reference” and “Incorporation of Certain Documents by Reference.”

 In response to the Staff’s verbal comment, the company
has revised the list of documents under the headings “Documents Incorporated by Reference” and “Incorporation of Certain
Documents by Reference,” to add hyperlinks directing to the location of these filings on the SEC’s Electronic Data Gathering,
Analysis, and Retrieval system.

 * * *

 We thank you for your prompt attention to this letter responding
to the Staff’s Comment Letter and look forward to hearing from you at your earliest convenience. Please direct any questions concerning
this filing to the undersigned at (226) 979- 6699 or tmell@electrabmc.com.

 Sincerely,

 /s/ Trent Mell

 Chief Executive Officer

 Electra Battery Materials Corporation

 cc:

 Via Email
 Thomas M. Rose, Troutman Pepper Locke LLP
 Shona C. Smith, Troutman Pepper Locke LLP

 2

August 6, 2025
Trent Mell
Chief Executive Officer
Electra Battery Materials Corporation
133 Richmond Street W, Suite 602
Toronto, ON M5H 2L3
Canada
Re:Electra Battery Materials Corporation
Amendment No. 1 to Registration Statement on Form F-3
Filed July 28, 2025
File No. 333-288364
Dear Trent Mell:
            We have reviewed your amended registration statement and have the following
comment.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our July 21, 2025 letter.
Amendment No. 1 to Registration Statement on Form F-3
Exhibits
1.We note the opinion filed as Exhibit 5.2 regarding the legality of the common shares
that may be issued pursuant to the "at the market" offering prospectus supplement.
Please obtain and file a revised legality opinion to ensure that the opinion does not
contain assumptions that are overly broad, that “assume away” the relevant issue, or
that assume any of the material facts underlying the opinion or any readily
ascertainable facts. Refer to Staff Legal Bulletin 19 at Sections II.B.2.a and II.B.3.a.

August 6, 2025
Page 2
            Please contact Michael Purcell at 202-551-5351 or Laura Nicholson at 202-551-3584
with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Thomas Rose

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 29, 2025

Marty Rendall
Chief Financial Officer
Electra Battery Materials Corp
133 Richmond Street West, Suite 602
Toronto, ON M5H 2L3

 Re: Electra Battery Materials Corp
 Form 20-F for the Fiscal Year ended December 31, 2024
 Filed April 24, 2025
 File No. 001-41356
Dear Marty Rendall:

 We have completed our review of your filing. 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.

 Sincerely,

 Division of Corporation
Finance
 Office of Energy &
Transportation
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 Electra Battery Materials Corporation

 133 Richmond Street West, Suite 602

 Toronto, ON M5H 2L3

 Canada

 https://www.electrabmc.com/

 July 25, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 100 F. Street, N.E.

 Washington, D.C. 20549

 Attention: Jenifer Gallagher and John Cannarella

 Re:

 Electra Battery Materials Corporation
 Form 20-F for the Fiscal Year Ended December 31, 2024
 Filed April 24, 2025
 File No. 001-41356

 Ladies and Gentlemen:

 I am submitting this letter on behalf of Electra Battery Materials Corporation
(the " Company "), in response to the written comments of the staff (the " Staff ") of the U.S. Securities
and Exchange Commission (the " SEC "), contained in the Staff's letter, dated July 18, 2025 (the " Comment
Letter "), in connection with the Company's Form 20-F for the Fiscal Year Ended December 31, 2024, filed with the SEC on
April 24, 2025 (the " Form 20-F ").

 For your convenience, the Company's responses are set forth below,
with the headings and numbered items of this letter corresponding to the headings and numbered items contained in the Comment Letter.
Each of the comments from the Comment Letter is restated in bold and italics prior to the Company's response.

 Form 20-F for the Fiscal Year Ended December 31, 2024

Controls and Procedures, page 96

 1. We note your disclosure indicating that significant deficiencies had been identified and resulted in
the conclusions that your internal control over financial reporting and disclosure controls and procedures were not effective as
of December 31, 2024.

 However, in the Report of Management's
 Accountability on page 2 of your financial statements, you have disclosure indicating
 that management identified material weaknesses in your internal control over financial
 reporting and disclosure controls and procedures related to the year ended December
 31, 2024.

 Please revise as necessary to clarify whether material weaknesses or significant
 deficiencies were identified. You may refer to the definitions of these terms in Rule 1-02(a)(4) of Regulation
 S-X and AS 2201.A7 and .A11 for further clarification.

 Please also expand your disclosures to describe any material weaknesses in
 your internal control over financial reporting to comply with Item 15(b)(3) of Form 20-F.

 Securities and Exchange Commission July 25, 2025 Page 2

 The Company has revised the Item 15 disclosure regarding Controls
and Procedures under the subheadings "Disclosure Controls and Procedures" and "Management Report on Internal Control
Over Financial Reporting" on page 96 of the Form 20-F to clarify that the Company identified material weaknesses in the internal
controls over financial reporting and disclosure controls and procedures over the course of the first three quarters of the fiscal year
ended December 31, 2024, but that improvements to its internal controls over financial reporting and disclosure controls and procedures
were made by the Company in each of the third and fourth quarters of the fiscal year ended December 31, 2024, such that the previously
identified material weaknesses had become significant deficiencies by the end of the fiscal year on December 31, 2024. The Company has
also made corresponding changes to the Report of Management's Accountability contained on page 2 of its annual consolidated financial
statement for the fiscal years ended December 31, 2024, 2023 and 2022 included in the Form 20-F.

 The Company has also added disclosure in Item 15 of the Form
20-F describing the material weaknesses in the internal controls over financial reporting and disclosure controls and procedures, which
include the following:

 (i) An ineffective control environment resulting from the combination of an insufficient number of trained
financial reporting and accounting personnel with the appropriate skills and knowledge regarding the design, implementation, and operation
of internal control over financial reporting.

 (ii) Management had not designed or implemented a control monitoring process necessary to identify control
weaknesses and remediations in a timely manner necessary to ensure the reliability of its internal control over financial reporting.

 (iii) Control deficiencies in procurement and payment resulting from a lack of formal processes and inconsistent
receiving processes at the Company's refinery project.

 2. We note your disclosure under the heading Changes in Internal Control over Financial Reporting
on page 97, stating that while substantial progress has been made in strengthening internal control over financial reporting
during 2024, management continues to assess and enhance internal controls of the company.

 Given the requirement to disclose any change in your internal control
 over financial reporting that occurred during the period that materially affected, or is reasonably likely to materially
 affect, your internal control over financial reporting under Item 15(d) of Form 20-F, please revise to describe the
 progress to which you refer and to clarify the nature of its effect on your internal control over financial reporting.

 With regard to your disclosure stating Electra has not yet implemented "the
 full suite of systems, processes, and personnel typically found in more mature organizations," clarify the extent
 to which this refers to aspects of the controls and procedures that your officers designed, as referenced in their certifications,
 and describe your plans for implementation and dates for resolving the deficiencies or weaknesses.

 The Company has revised the Item 15 disclosure regarding Controls
and Procedures under the subheading "Changes in Internal Control over Financial Reporting" to describe the material improvements
that were made over the course of each of the third and fourth quarters of the fiscal year ended December 31, 2024 to the internal control
over financial reporting, as well to describe the additional improvements that the Company intends to take when its primary assets are
brought out of care and maintenance mode when such additional improvements are warranted. The Company is proposing to add the following
disclosure under the subheading "Changes in Internal Control over Financial Reporting":

 "The Company's CEO and CFO identified the following
areas where material improvements were made during the fourth quarter of fiscal 2024.

 · Control Environment

 o The Company increased the number of trained financial reporting and accounting personnel with the appropriate
skills and knowledge regarding the design, implementation, and operation of internal controls over financing reporting.

 2
 Securities and Exchange Commission July 25, 2025 Page 3

 · Control Monitoring Process

 o The Company implemented a control monitoring process to identify weaknesses in its internal control over
financial reporting.

 · Procurement, Payment and Receiving Processes

 o The Company improved reporting and receiving processes to ensure adherence to the Company's policies
at the Company's refinery project.

 The Company's primary assets, including its hydrometallurgical
refinery in Ontario, Canada and its cobalt exploration properties in Idaho, USA, are currently on care and maintenance. One or both of
these assets are expected to become more active during fiscal 2025 and 2026, at which time, the Company intends to further enhance and
improve its internal control over financial reporting appropriately for such additional activities. Specific areas of focus are expected
to be: (i) the control environment, including IT infrastructure and processes, and internal audit function; (ii) the control monitoring
process; (iii) the payroll process; (iv) the property, plant and equipment process; and (v) the procurement, payment and receiving processes."

 Exhibits

 3. The certifications at Exhibits 12.1 and 12.2 do not include all of the language required in paragraph
4, specifically as it relates to the officers acknowledging responsibility for establishing and maintaining internal control over
financial reporting.

 Please amend the filing to include officer certifications that include all of the
 language prescribed in paragraph 12 of the Instructions as to Exhibits of Form 20-F.

 The Company has amended the Form 20-F to include officer certifications
that include all of the language prescribed in paragraph 12 of the Instructions as to Exhibits of Form 20-F.

 * * *

 We thank you for your prompt attention to this letter responding
to the Staff's Comment Letter and look forward to hearing from you at your earliest convenience. Please direct any questions concerning
this filing to the undersigned at (226) 979- 6699 or mrendall@electrabmc.com.

 Sincerely,

 /s/ Marty Rendall

 Chief Financial Officer

 Electra
Battery Materials Corp

 cc:

 Via Email
 Thomas M. Rose, Troutman Pepper Locke LLP
 Shona C. Smith, Troutman Pepper Locke LLP

 3

CORRESP
1
filename1.htm

Electra Battery Materials Corporation

133 Richmond Street West, Suite 602

Toronto, ON M5H 2L3

Canada

https://www.electrabmc.com/

July 25, 2025

VIA EDGAR

U.S. Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549

Attention: Michael Purcell and Laura Nicholson

    Re:

    Electra Battery Materials Corporation

    Registration Statement on Form F-3

    Filed June 27, 2025

    File No. 333-288364

Ladies and Gentlemen:

I am submitting this letter on behalf of Electra Battery Materials Corporation
(the “Company”), in response to the written comments of the staff (the “Staff”) of the U.S. Securities
and Exchange Commission (the “SEC”), contained in the Staff’s letter, dated July 21, 2025 (the “Comment
Letter”), in connection with the Company’s Registration Statement on Form F-3, filed with the SEC on June 27, 2025 (the
“Form F-3”).

In response to the comments set forth in the Comment Letter, the Company
has revised the Form F-3 as further described below and is filing an amendment to the Form F-3 with this response letter.

For your convenience, the Company’s responses are set forth below,
with the headings and numbered items of this letter corresponding to the headings and numbered items contained in the Comment Letter.
Each of the comments from the Comment Letter is restated in bold and italics prior to the Company’s response.

Registration Statement on Form F-3

Signatures, page II-6

 1. Please ensure that you have provided all signatures required by Form F-3. For example, we note that
you have not provided a signature for C.L. “Butch” Otter or a full signature for Alden Greenhouse.

The Company notes that Instruction 1 to the Signatures portion of Form
F-3 permits a registration statement on Form F-3 to be signed by “at least a majority of the of the board of directors or persons
performing similar functions”. However, the Company has revised the Form F-3 to note that we have now received signatures to the
Form F-3 from all members of the board of directors of the Company.

    Securities and Exchange Commission

July 25, 2025

Page 2

Exhibits

 2. Please obtain and file an opinion that opines on the legality of the common shares that may be issued
pursuant to the “at the market” offering prospectus supplement.

The Company has revised the Form F-3 to include Exhibit 5.2 which opines
on the legality of the common shares that may be issued pursuant to the “at the market” offering prospectus supplement.

General

 3. Please confirm your understanding that we will not be in a position to take action to accelerate
the effectiveness of your registration statement until our comments relating to your Form 20-F for the fiscal year ended December
31, 2024 have been resolved.

The Company confirms its understanding that the Staff will not be in a
position to take action to accelerate the effectiveness of the Form F-3 until our comments relating to our Form 20-F for the fiscal year
ended December 31, 2024 have been resolved. The Company has submitted a Response Letter to the Comment Letter received from the Staff
on the Form 20-F.

* * *

We thank you for your prompt attention to this letter responding
to the Staff’s Comment Letter and look forward to hearing from you at your earliest convenience. Please direct any questions concerning
this filing to the undersigned at (226) 979- 6699 or tmell@electrabmc.com.

  Sincerely,

  /s/ Trent Mell

  Chief Executive Officer

  Electra Battery Materials Corporation

    cc:

    Via Email

    Thomas M. Rose, Troutman Pepper Locke LLP

    Shona C. Smith, Troutman Pepper Locke LLP

2

July 21, 2025
Trent Mell
Chief Executive Officer
Electra Battery Materials Corp
133 Richmond Street W, Suite 602
Toronto, ON M5H 2L3
Canada
Re:Electra Battery Materials Corp
Registration Statement on Form F-3
Filed June 27, 2025
File No. 333-288364
Dear Trent Mell:
            We have conducted a limited review of your registration statement and have the
following comments.
            Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Registration Statement on Form F-3
Signatures, page II-6
1.Please ensure that you have provided all signatures required by Form F-3. For
example, we note that you have not provided a signature for C.L. “Butch” Otter or a
full signature for Alden Greenhouse.
Exhibits
2.Please obtain and file an opinion that opines on the legality of the common shares that
may be issued pursuant to the "at the market" offering prospectus supplement.

July 21, 2025
Page 2
General
3.Please confirm your understanding that we will not be in a position to take action to
accelerate the effectiveness of your registration statement until our comments relating
to your Form 20-F for the fiscal year ended December 31, 2024 have been resolved.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Michael Purcell at 202-551-5351 or Laura Nicholson at 202-551-3584
with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Thomas Rose

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 18, 2025

Marty Rendall
Chief Financial Officer
Electra Battery Materials Corp
133 Richmond Street West, Suite 602
Toronto, ON M5H 2L3

 Re: Electra Battery Materials Corp
 Form 20-F for the Fiscal Year ended December 31, 2024
 Filed April 24, 2025
 File No. 001-41356
Dear Marty Rendall:

 We have reviewed your filing and have the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 20-F for the Fiscal Year ended December 31, 2024
Controls and Procedures, page 96

1. We note you disclosure indicating that significant deficiencies had been
identified and
 resulted in the conclusions that your internal control over financial
reporting and
 disclosure controls and procedures were not effective as of December 31,
2024.

 However, in the Report of Management s Accountability on page 2 of
your financial
 statements, you have disclosure indicating that management identified
material
 weaknesses in your internal control over financial reporting and
disclosure controls
 and procedures related to the year ended December 31, 2024.

 Please revise as necessary to clarify whether material weaknesses or
significant
 deficiencies were identified. You may refer to the definitions of these
terms in Rule 1-
 02(a)(4) of Regulation S-X and AS 2201.A7 and .A11 for further
clarification.

 Please also expand your disclosures to describe any material weaknesses
in your
 internal control over financial reporting to comply with Item 15(b)(3)
of Form 20-F.
 July 18, 2025
Page 2

2. We note your disclosure under the heading Changes in Internal Control
over Financial
 Reporting on page 97, stating that while substantial progress has been
made in
 strengthening internal control over financial reporting during 2024,
management
 continues to assess and enhance internal controls of the company.

 Given the requirement to disclose any change in your internal control
over financial
 reporting that occurred during the period that materially affected, or
is reasonably
 likely to materially affect, your internal control over financial
reporting under Item
 15(d) of Form 20-F, please revise to describe the progress to which you
refer and to
 clarify the nature of its affect on your internal control over financial
reporting.

 With regard to your disclosure stating Electra has not yet implemented
"the full suite
 of systems, processes, and personnel typically found in more mature
organizations,"
 clarify the extent to which this refers to aspects of the controls and
procedures that
 your officers designed, as referenced in their certifications, and
describe your plans
 for implementation and dates for resolving the deficiencies or
weaknesses.

Exhibits

3. The certifications at Exhibits 12.1 and 12.2 do not include all of the
language required
 in paragraph 4, specifically as it relates to the officers acknowledging
responsibility
 for establishing and maintaining internal control over financial
reporting.

 Please amend the filing to include officer certifications that include
all of the language
 prescribed in paragraph 12 of the Instructions as to Exhibits of Form
20-F.

 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.

 Please contact Jenifer Gallagher at 202-551-3706 or John Cannarella at
202-551-3337
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
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