SecProbe.io

CORRESP
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 ThinkEquity LLC

 17 State Street, 41 st Floor

 New York, NY 10004

 August 12, 2025

 VIA EDGAR

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street NE

 Washington, D.C. 20549

 Re:
 Vision Marine Technologies Inc. (the "Company")

 Registration Statement on Form F-1 (the "Registration Statement")

 Filed August 12, 2025

 Ladies and Gentlemen:

 In connection with the above-referenced Registration
Statement, and pursuant to Rule 461 under the Securities Act of 1933 , as amended (the " Act "), we, the underwriter,
hereby join in the request of the Company that the effective date of the Registration Statement be accelerated so that it will be declared
effective at 5:00 pm, Eastern Time (US), on August 14, 2025, or soon as thereafter practicable.

 Pursuant to Rule 460 under the Act, we wish to
advise you that we will distribute as many copies of the Preliminary Prospectus dated August 12, 2025 to underwriters, dealers, institutions
and others as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus.

 We, the underwriter, have complied and will comply
with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 Very truly yours,

 ThinkEquity LLC

 /s/
 Eric Lord

 Eric Lord

 Head of Investment Banking

CORRESP
 1
 filename1.htm

 August 12, 2025

 VIA EDGAR

 United State Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, DC 20549

 Re:
 Vision Marine Technologies Inc. (the "Company")

 Registration
Statement on Form F-1

 File No.
333-289547 (the "Registration Statement")

 Ladies and Gentlemen:

 The Company hereby requests,
pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the "Securities Act"), acceleration of the
effectiveness of the above-referenced Registration Statement so that such Registration Statement will become effective as of 5:00pm Eastern
Standard Time on Thursday, August 14, 2025, or as soon thereafter as practicable.

 The Company understands that the United State
Securities and Exchange Commission will consider this request for acceleration of the effective date of the Registration Statement as
a confirmation of the fact that the Company is aware of its responsibilities under the Securities Act as they relate to the proposed public
offering of the securities specified in the Registration Statement.

 The undersigned respectfully
requests that it be notified of the effectiveness of the above-referenced Registration Statement by telephone call to our counsel, Ortoli
Rosenstadt LLP, by calling Tim Dockery at (212) 829-8946. The Company hereby authorizes Mr. Dockery to orally modify or withdraw this
request for acceleration.

 Very truly yours,

 VISION MARINE TECHNOLOGIES INC.

 By:
 /s/ Raffi Sossoyan

 Name:
 Raffi Sossoyan

 Title:
 Chief Financial Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 30, 2025

Alexandre Mongeon
Chief Executive Officer
Vision Marine Technologies Inc.
730 Boulevard du Cur -Boivin
Boisbriand, Qu bec J7G 2A7, Canada

 Re: Vision Marine Technologies Inc.
 Draft Registration Statement on Form F-1
 Submitted on July 25, 2025
 CIK 0001813783
Dear Alexandre Mongeon:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement at least
two business
days prior to the requested effective date and time. Please refer to Rules 460
and 461
regarding requests for acceleration. 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 Sarah Sidwell at 202-551-4733 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
cc: Tim Dockery
</TEXT>
</DOCUMENT>

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January 29, 2025

Via EDGAR and E-mail

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549-4720

    Re:
    Vision Marine Technologies Inc.

    Registration Statement on Form F-3

    File No. 	333-284423

    Acceleration Request

    Requested Date: January 31, 2025

    Requested Time: 5:00 P.M. Eastern Time

Ladies and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Vision Marine Technologies Inc. (the “Company”) hereby requests
that the above-referenced Registration Statement on Form F-3 (Registration No. 333-284423) (the “Registration Statement”)
be declared effective at the “Requested Date” and “Requested Time” set forth above or at such later time as the
Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and
Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Ortoli
Rosenstadt LLP, by calling Tim Dockery at (212) 829-8946.

* * * *

    Sincerely,

    VISION MARINE TECHNOLOGIES INC.

    /s/ Raffi Sossoyan

    Raffi Sossoyan

January 29, 2025
Alexandre Mongeon
Chief Executive Officer
Vision Marine Technologies Inc.
730 Boulevard du Curé-Boivin
Boisbriand, Québec J7G 2A7, Canada
Re:Vision Marine Technologies Inc.
Registration Statement on Form F-3
Filed January 23, 2025
File No. 333-284423
Dear Alexandre Mongeon:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Erin Donahue at 202-551-6063 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

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February 5, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

    Re:
    Vision Marine Technologies Inc.

Registration
Statement on Form F-1

File No.
333-276772

Ladies and Gentlemen:

The Company hereby requests,
pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), acceleration of the
effectiveness of the above-referenced Registration Statement so that such Registration Statement will become effective as of 4:00pm Eastern
Standard Time on Wednesday, February 7, 2024, or as soon thereafter as practicable.

The Company understands
that the Commission will consider this request for acceleration of the effective date of the Registration Statement as a confirmation
of the fact that the Company is aware of its responsibilities under the Securities Act as they relate to the proposed public offering
of the securities specified in the Registration Statement.

The undersigned respectfully
requests that it be notified of the effectiveness of the above-referenced Registration Statement by telephone call to our counsel, Ortoli
Rosenstadt LLP, by calling Tim Dockery at (212) 829-8946. The Company hereby authorizes Mr. Dockery to orally modify or withdraw this
request for acceleration.

Very truly yours,

VISION MARINE TECHNOLOGIES INC.

    By:
    /s/ Kulwant Sandher

    Name:
    Kulwant Sandher

    Title:
    Chief Financial Officer

United States securities and exchange commission logo
February 2, 2024
Alexandre Mongeon
Chief Executive Officer
Vision Marine Technologies Inc.
730 Boulevard du Curé-Boivin
Boisbriand, Québec J7G 2A7, Canada
Re:Vision Marine Technologies Inc.
Registration Statement on Form F-1
Filed on January 30, 2024
File No. 333-276772
Dear Alexandre Mongeon:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Bradley Ecker at 202-551-4985 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

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JOSEPH GUNNAR & CO., LLC

30 Broad Street, 11th Floor

New York, NY 10004

December 4, 2023

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

 Re: Vision Marine Technologies Inc.

Registration Statement on Form F-1

(File No. 333-275503) (the “Registration
Statement”)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act
of 1933, as amended (the “Securities Act”), the undersigned underwriter in connection with the above referenced Registration
Statement relating to the offer and issuance by the Registrant of certain of its securities, hereby joins the Registrant’s request
that the effective date of the Registration Statement be accelerated so that it shall be declared effective at 5:00 p.m. Eastern Time
on Monday, December 4, 2023, or as soon thereafter as practicable.

Pursuant to Rule 460 under the Act, we wish to
advise you that the underwriters have distributed as many copies of the Preliminary Prospectus, dated December 4, 2023, to underwriters,
dealers, institutions and others as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

This is to further advise you that the underwriters
have and will continue to comply with Rule 15c2-8 of the Securities Exchange Act of 1934, as amended, with regard to the Preliminary Prospectus
and any amended Prospectus.

    Very
    truly yours,

    JOSEPH
    GUNNAR & CO., LLC

    By:
    /s/ Stephan Stein

    Name:
    Stephan Stein

    Title:
    President

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December 4, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

    Re:
    Vision Marine Technologies Inc.

Registration
Statement on Form F-1

File No.
333-275503

Ladies and Gentlemen:

The Company hereby requests,
pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), acceleration of the
effectiveness of the above-referenced Registration Statement so that such Registration Statement will become effective as of 5:00pm Eastern
Time on Monday, December 4, 2023, or as soon thereafter as practicable.

The Company understands
that the Commission will consider this request for acceleration of the effective date of the Registration Statement as a confirmation
of the fact that the Company is aware of its responsibilities under the Securities Act as they relate to the proposed public offering
of the securities specified in the Registration Statement.

The undersigned respectfully
requests that it be notified of the effectiveness of the above-referenced Registration Statement by telephone call to our counsel, Ortoli
Rosenstadt LLP, by calling Tim Dockery at (212) 829-8946. The Company hereby authorizes Mr. Dockery to orally modify or withdraw this
request for acceleration.

Very truly yours,

VISION MARINE TECHNOLOGIES INC.

    By:
    /s/ Kulwant Sandher

    Name:
    Kulwant Sandher

    Title:
    Chief Financial Officer

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November 29, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

    Re:
    Vision Marine Technologies Inc.

    Registration
Statement on Form F-1

    File No.
333-275503

Ladies and Gentlemen:

Reference is made to
our letter, filed as correspondence via EDGAR on November 28, 2023, in which we requested the acceleration of the effective date of the
above-referenced Registration Statement for Wednesday, November 29, 2023, at 5:00 p.m. Eastern Time, 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 this time,
and we hereby formally withdraw our request for acceleration of the effective date.

Very truly yours,

VISION MARINE TECHNOLOGIES INC.

    By:
    /s/ Kulwant Sandher

    Name:
    Kulwant Sandher

    Title:
    Chief Financial Officer

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JOSEPH
GUNNAR & CO., LLC

30
Broad Street, 11th Floor

New York, NY 10004

November 28, 2023

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

 Re: Vision Marine Technologies Inc.

    Registration Statement on Form F-1

    (File No. 333-275503) (the “Registration Statement”)

Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act
of 1933, as amended (the “Securities Act”), the undersigned underwriter in connection with the above referenced Registration
Statement relating to the offer and issuance by the Registrant of certain of its securities, hereby joins the Registrant’s request
that the effective date of the Registration Statement be accelerated so that it shall be declared effective at 5:00 p.m. Eastern Time
on Wednesday, November 29, 2023, or as soon thereafter as practicable.

Pursuant to Rule 460 under the Act, we wish to
advise you that the underwriters have distributed as many copies of the Preliminary Prospectus, dated November 27, 2023, to underwriters,
dealers, institutions and others as appears to be reasonable to secure adequate distribution of the preliminary prospectus.

This is to further advise you that the underwriters
have and will continue to comply with Rule 15c2-8 of the Securities Exchange Act of 1934, as amended, with regard to the Preliminary Prospectus
and any amended Prospectus.

  Very truly yours,

  JOSEPH GUNNAR & CO., LLC

  By:
  /s/ Stephan Stein

  Name:
  Stephan Stein

  Title:
  President

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November 28, 2023

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

Re: Vision
Marine Technologies Inc.

Registration Statement on Form F-1

File No. 333-275503

Ladies and Gentlemen:

The Company hereby requests,
pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), acceleration of the
effectiveness of the above-referenced Registration Statement so that such Registration Statement will become effective as of 5:00pm Eastern
Time on Wednesday, November 29, 2023, or as soon thereafter as practicable.

The Company understands
that the Commission will consider this request for acceleration of the effective date of the Registration Statement as a confirmation
of the fact that the Company is aware of its responsibilities under the Securities Act as they relate to the proposed public offering
of the securities specified in the Registration Statement.

The undersigned respectfully
requests that it be notified of the effectiveness of the above-referenced Registration Statement by telephone call to our counsel, Ortoli
Rosenstadt LLP, by calling Tim Dockery at (212) 829-8946. The Company hereby authorizes Mr. Dockery to orally modify or withdraw this
request for acceleration.

Very truly yours,

VISION MARINE TECHNOLOGIES INC.

    By:
    /s/ Kulwant Sandher

    Name:
    Kulwant Sandher

    Title:
    Chief Financial Officer

United States securities and exchange commission logo
November 16, 2023
Alexandre Mongeon
Chief Executive Officer
Vision Marine Technologies Inc.
730 Boulevard du Curé-Boivin
Boisbriand, Québec J7G 2A7, Canada
Re:Vision Marine Technologies Inc.
Registration Statement on Form F-1
Filed November 13, 2023
File No. 333-275503
Dear Alexandre Mongeon:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Jenny O'Shanick at 202-551-8005 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Tim Dockery

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October 13, 2023

Via EDGAR and E-mail

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549-4720

    Re:
    Vision Marine Technologies Inc.

    Registration Statement on Form F-3

    File No. 333-274882

    Acceleration Request

    Requested Date: October 17, 2023

    Requested Time: 5:00 P.M. Eastern Time

Ladies and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Vision Marine Technologies Inc. (the “Company”) hereby requests
that the above-referenced Registration Statement on Form F-3 (Registration No. 333-274882) (the “Registration
Statement”) be declared effective at the “Requested Date” and “Requested Time” set forth above or at such
later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of
the Securities and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event
with our counsel, Dentons US LLP, by calling Rob Condon at (212) 768-6839.

* * * *

    Sincerely,

    VISION MARINE TECHNOLOGIES INC.

    /s/ Kulwant Sandher

    Kulwant Sandher

    cc:
    Rob Condon, Dentons US LLP

United States securities and exchange commission logo
October 13, 2023
Kulwant Sandher
Chief Financial Officer
Vision Marine Technologies Inc.
730 Boulevard du Curé-Boivin
Boisbriand, Quebec J7G 2A7, Canada
Re:Vision Marine Technologies Inc.
Registration Statement on Form F-3
Filed October 5, 2023
File No. 333-274882
Dear Kulwant Sandher:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Gregory Herbers at 202-551-8028 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Rob Condon

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December 19, 2022

Via EDGAR and E-mail

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549-4720

    Re:
    Vision Marine Technologies Inc.

    Registration Statement on Form F-3

    File No. 333-267893

    Acceleration Request

    Requested Date: December 21, 2022

    Requested Time: 5:00 P.M. Eastern Time

Ladies and Gentlemen:

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Vision Marine Technologies Inc. (the “Company”) hereby requests
that the above-referenced Registration Statement on Form F-3 (Registration No. 333-267893) (the “Registration
Statement”) be declared effective at the “Requested Date” and “Requested Time” set forth above or at such
later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of
the Securities and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event
with our counsel, Dentons US LLP, by calling Rob Condon at (212) 768-6839.

* * * *

    Sincerely,

    VISION MARINE TECHNOLOGIES INC.

    /s/ Kulwant Sandher

    Kulwant Sandher

    cc:
    Rob Condon, Dentons US LLP

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Vision Marine Technologies Inc.

730 Boulevard du Curé-Boivin

Boisbriand, Québec, J7G 2A7, Canada

  December 13, 2022

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-6010

Attention: Thomas Jones

  Jay Ingram

Re: Vision Marine Technologies Inc.

  Registration Statement on Form F-3

Filed October 14, 2022

File No. 333-267893

CIK No. 0001813783

Ladies and Gentlemen:

Set forth below is Vision Marine Technologies Inc.’s (the “Company”)
response to the comment of the Staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission
(the “Commission”) relating to the Company’s Registration Statement on Form F-3 (File No. 333-267893) (the “Registration
Statement”), in the Staff’s letter to the Company, dated October 31, 2022, relating to the Registration Statement. For convenience
of reference, the text of the comment in the Staff’s letter has been reproduced in bold and italics herein. The Company has provided
its response immediately after the comment. Concurrently with this letter, the Company is filing Amendment No. 1 to the Registration Statement
(the “Amendment”) with the Commission.

Registration Statement on Form F-3 filed October 14, 2022

General

1. We note that on June 10, 2021 you filed a Form 6-K to announce
the acquisition of Electric Boat Rental Ltd. Please provide an analysis regarding the financial statement requirements of Rule 3-05 of
Regulation S-X for this acquisition.

Response: The Company respectfully acknowledges the Staff’s
comment and advises the Staff that the results of operations of the Electric Boat Rental Ltd. (“EBR”) business following the
acquisition have been included in the Company’s audited financial statements for the year ended August 31, 2021 (from June 3, 2021),
in the Company’s financial statements for the three, six and nine months ended November 30, 2021, February 28, 2022, and May 31,
2022, respectively, and included in the Company’s audited financial statements for the year ended August 31, 2022 included in the
Company’s Annual Report on Form 20-F for the year ended August 31, 2022 filed on November 30, 2022 with the Commission (the “Annual
Report”). Accordingly, the operating results of EBR have been reflected in the audited consolidated financial statements of the
Company for a complete fiscal year in compliance with Rule 3-05(b)(4)(iii) of Regulation S-X, and the Company’s Annual Report has
been incorporated by reference into the Amendment.

I hope the foregoing answer is responsive to your comment. Please do
not hesitate to contact me by telephone at (604) 720-6468 with any questions or comments regarding this correspondence.

    Very truly yours,

    By:
    /s/ Kulwant Sandher

    Name: Kulwant Sandher

    Title: Chief Financial Officer

cc:         Rob Condon, Esq., Dentons US LLP

United States securities and exchange commission logo
October 31, 2022
Alexandre Mongeon
Chief Executive Officer
Vision Marine Technologies Inc.
730 Boulevard du Cure-Boivin
Boisbriand, Quebec J7G 2A7, Canada
Re:Vision Marine Technologies Inc.
Registration Statement on Form F-3
Filed October 14, 2022
File No. 333-267893
Dear Alexandre Mongeon:
            We have limited our review of your registration statement to those issues we have
addressed in our 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form F-3 filed October 14, 2022
General
1.We note that on June 10, 2021 you filed a Form 6-K to announce the acquisition of
Electric Boat Rental Ltd.  Please provide an analysis regarding the financial statement
requirements of Rule 3-05 of Regulation S-X for this acquisition.
            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.

 FirstName LastNameAlexandre Mongeon
 Comapany NameVision Marine Technologies Inc.
 October 31, 2022 Page 2
 FirstName LastName
Alexandre Mongeon
Vision Marine Technologies Inc.
October 31, 2022
Page 2
            Please contact Thomas Jones, Staff Attorney, at 202-551-3602 or Jay Ingram, Legal
Branch Chief, at 202-551-3397 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       Rob Condon, Esq.

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ThinkEquity

A division of Fordham Financial Management,
Inc.

17 State Street, 22nd Floor

New York, NY 10004

November
20, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F St., N.E.

Washington, D.C. 20549

 Re: Vision Marine Technologies Inc.

Registration Statement on Form F-1

File No. 333-239777

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the
Securities Act of 1933, as amended (the “Securities Act”), ThinkEquity, a division of Fordham Financial Management,
Inc., as representative of the underwriters, hereby requests acceleration of the effective date of the above-referenced Registration
Statement so that it will become effective at 5:00 p.m. Eastern Time on November 23, 2020 or as soon thereafter as practicable.

Pursuant to Rule 460 under the Securities
Act, please be advised that there will be distributed to each underwriter, who is reasonably anticipated to be invited to participate
in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable
to secure adequate distribution of the preliminary prospectus.

The undersigned confirms that it has complied
with and will continue to comply with, and it has been informed or will be informed by participating dealers that they have complied
with or will comply with, Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended, in connection with the
above-referenced issue.

    Very truly yours,

    ThinkEquity

    A division of Fordham Financial Management, Inc.

    By:
    /s/ Eric Lord

    Name:
    Eric Lord

    Title:
    Head of Investment Banking

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Vision Marine
Technologies Inc.

730 Boulevard
du Curé-Boivin

Boisbriand, Québec J7G 2A7, Canada

November 20, 2020

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, DC 20549

 Re: Vision Marine Technologies, Inc.

Registration
Statement on Form F-1

File No. 333-239777

Ladies and Gentlemen:

The
Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended (the “Securities Act”),
acceleration of the effectiveness of the above-referenced Registration Statement so that such Registration Statement will become
effective as of 5:00pm Eastern Time on Monday, November 23, 2020, or as soon thereafter as practicable.

The Company understands that the Commission will consider this
request for acceleration of the effective date of the Registration Statement as a confirmation of the fact that the Company is
aware of its responsibilities under the Securities Act as they relate to the proposed public offering of the securities specified
in the Registration Statement.

The undersigned
respectfully requests that it be notified of the effectiveness of the above-referenced Registration Statement by telephone call
to our counsel, Ortoli Rosenstadt LLP, by calling Tim Dockery at (212) 829-8946. The Company hereby authorizes Mr. Dockery to orally
modify or withdraw this request for acceleration.

Very truly yours,

VISION MARINE TECHNOLOGIES INC.

    By:
    /s/Kulwant Sandher

    Name:
    Kulwant Sandher

    Title:
    Chief Financial Officer

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November
5, 2020

Division
of Corporation Finance

Office
of Manufacturing

U.S. Securities
and Exchange Commission

Washington,
D.C. 20549-4720

Via EDGAR

 Re: Vision Marine Technologies Inc.

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

Filed October
19, 2020

File No. 333-239777

This letter is
in response to your letter of October 28, 2020 in which you provided comments to amendment number three to the registration
statement on Form F-1 (“Amendment No. 3”) of Vision Marine Technologies Inc. (the “Company”) filed
with the U.S. Securities and Exchange Commission on October 19, 2020. On the date hereof, the Company has filed amendment
number four to the registration statement on Form F-1 (“Amendment No. 4”). We set forth below in bold each comment in your letter relating to Amendment No. 3 followed by our response to the comment.

Amendment No. 3 to Registration Statement
on Form F-1 filed October 19, 2020

Capitalization, page 30

 1. We note the revisions made in response to prior comment 3. Please further revise the table to
address the following:

 • Include a double line under the cash and cash equivalents
amounts and revise the first line of the introductory paragraph to indicate that the table presents your cash and cash equivalents
and capitalization.

 • Replace the itemized current and non-current liabilities
sections with a Debt section that only includes the line items of Bank indebtedness, Current portion of long term debt and Long-term
debt (non-current portion); all other liability line items should be deleted from the table.

 • Recalculate your Total Capitalization amounts to
reflect only the summation of Bank indebtedness, Current portion of long term debt, Long-term debt (non-current portion) and Total
Equity (Deficit).

We have revised
the table in Amendment No. 4 accordingly.

Summary Compensation Table, page
64

 2. We note your response to prior comment 2 and the new disclosure in the table on page 64 about
the amount of Share-based awards" and "Option-based awards" for the fiscal year ended August 31, 2020. Regarding
the portion of compensation that was paid: (1) pursuant to a bonus or profit-sharing plan, provide a brief description of the plan
and the basis upon which such persons participate in the plan; and (2) in the form of stock options, provide the title and amount
of securities covered by the options, the exercise price, the purchase price (if any), and the expiration date of the options.
For guidance, see Item 6.B.1. of Form 20-F.

We have revised
the disclosure in Amendment No. 4  accordingly.

Related-Party Transactions, page
70

 3. We note your response to prior comment 4. Please update the disclosure in the first bullet point
on page 71 to a more recent date.

We have revised
the disclosure in Amendment No. 4  accordingly.

In addition to the above
responses to your comments, we hereby acknowledge that (i) the Company is responsible for the adequacy and accuracy of the disclosure
in Amendment No. 4, (ii) comments from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the
 “Commission”) does not foreclose the Commission from taking any action with respect to the Registration Statement or
Amendment No. 4 and (iii) the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

    Sincerely,

    /s/ Kulwant Sandher

    Kulwant Sandher

    Chief Financial Officer

United States securities and exchange commission logo
October 28, 2020
Alexandre Mongeon
Chief Executive Officer
Vision Marine Technologies Inc.
730 Boulevard du Cure-Boivin
Boisbriand, Quebec J7G2A7, Canada
Re:Vision Marine Technologies Inc.
Amendment No. 3 to Registration Statement on Form F-1
Filed October 19, 2020
File No. 333-239777
Dear Mr. Mongeon:
            We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our October 5, 2020 letter.
Amendment No. 3 to Registration Statement on Form F-1 filed October 19, 2020
Capitalization, page 30
1.We note the revisions made in response to prior comment 3.  Please further revise the
table to address the following:

•Include a double line under  the cash and cash equivalents amounts and revise the
first line of the introductory paragraph to indicate that the table presents your cash
and cash equivalents and capitalization.
•Replace the itemized current and non-current liabilities sections with a Debt section
that only includes the line items of Bank indebtedness, Current portion of long term
debt and Long-term debt (non-current portion); all other liability line items should be

 FirstName LastNameAlexandre Mongeon
 Comapany NameVision Marine Technologies Inc.
 October 28, 2020 Page 2
 FirstName LastName
Alexandre Mongeon
Vision Marine Technologies Inc.
October 28, 2020
Page 2
deleted from the table.
•Recalculate your Total Capitalization amounts to reflect only the summation of Bank
indebtedness, Current portion of long term debt, Long-term debt (non-current
portion) and Total Equity (Deficit).
Summary Compensation Table, page 64
2.We note your response to prior comment 2 and the new disclosure in the table on page 64
about the amount of Share-based awards" and "Option-based awards" for the fiscal year
ended August 31, 2020. Regarding the portion of compensation that was paid:
(1) pursuant to a bonus or profit-sharing plan, provide a brief description of the plan and
the basis upon which such persons participate in the plan; and (2) in the form of stock
options, provide the title and amount of securities covered by the options, the exercise
price, the purchase price (if any), and the expiration date of the options.  For guidance, see
Item 6.B.1. of Form 20-F.
Related-Party Transactions, page 70
3.We note your response to prior comment 4. Please update the disclosure in the first bullet
point on page 71 to a more recent date.
            You may contact Beverly Singleton, Staff Accountant, at 202-551-3328 or Martin James,
Senior Advisor, at 202-551-3671 if you have questions regarding comments on the financial
statements and related matters.  Please contact Thomas Jones, Staff Attorney, at 202-551-3602 or
Asia Timmons-Pierce, Special Counsel, at 202-551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       William Rosenstadt, Esq.

CORRESP
1
filename1.htm

October
19, 2020

Division
of Corporation Finance

Office
of Manufacturing

U.S. Securities
and Exchange Commission

Washington,
D.C. 20549-4720

Via EDGAR

 Re: Vision Marine Technologies Inc.

Amendment
No. 2 to the Registration Statement on Form F-1

Filed
September 22, 2020

File
No. 333-239777

This letter is in
response to your letter of October 5, 2020 in which you provided a comment to amendment number two to the registration statement
on Form F-1 (“Amendment No. 2”) of Vision Marine Technologies Inc. (the “Company”) filed with the U.S.
Securities and Exchange Commission on September 22, 2020. On the date hereof, the Company has filed an amendment number 3 to the
Registration Statement on Form F-1 (the “Amendment No. 3”). We set forth below in bold and italics the comment in your
letter relating to Amendment No. 2 followed by our response to the comment.

Amendment
No. 2 to Registration Statement on Form F-1 filed September 22, 2020

Prospectus
Summary, page ii

 1. We note that you completed a 3.7-for-1 reverse stock split on September
3, 2020 and the exchange of 600 Class A shares, being the entire share capital of the company, for 13,850,916 Voting Common Shares
on January 20, 2020. Please revise all share and per share information in the filing, including the audited financial statements
and the notes thereto, to give retroactive effect to these capital structure changes. Refer to IAS 33.64, SAB Topic 4.C and PCAOB
Auditing Standard 4101.

Please note
that Amendment No. 3 contains restated financial statements for the year ended August 31, 2019 that contain revised share and per
share information reflecting (i) the 3.7-for-1 reverse stock split on September 3, 2020 and (ii) the 1:23,084.86 share exchange
on January 22, 2020. Corresponding share and per share date in Amendment No.3 have been revised as well.

Executive
Compensation, page 15

 2. Please update your executive compensation disclosure to include your
recently completed fiscal year. Please refer to Item 6.B. of Form 20-F.

We have revised
the disclosure in Amendment No. 3 accordingly.

Capitalization
and Indebtedness, page 17 3.

 3. Please refer to Item 3.B of the Form 20-F and revise the table to
address the following:

 • Delete the entire assets section since these amounts do not constitute
part of your capitalization.

 • Revise the liabilities section to only present your short- and long-term
debt amounts using the same captions shown on your interim balance sheet on page F-30.

 • Replace the line item 'Total Liabilities and Shareholders' Equity
(Deficit)' with the caption 'Total Capitalization', as that amount will be the summation of your short and long-term debt and total
equity (deficit).

 • Include a footnote to the pro forma column of the table that explains
how the proceeds from the sale of common shares issued since March 1, 2020 were used, including, for example, for working capital
or other purposes.

We have revised
the disclosure in Amendment No. 3 per your comment.

Related-Party
Transactions, page 50

 4. We note your disclosure that the amounts due to related parties were
as of February 29, 2020. Please update to reflect a more recent date.

We have updated
the date of the amounts due to related parties in Amendment No. 3 to be as of October 19, 2020. Please note that that the aggregate
amount due to related parties has not changed as a result of changing the date.

Note
15. Subsequent Events, page F-46

 5. We note your common stock and stock option issuances for cash and
services during the period from March 2020 through September 2020. We further note that the IPO price range is US$8.00 to US$10.00
per common stock, with a mid-point price of US$9.00 or CDN$12.07 per share and that the fair value of your common stock used to
value the issuances was CDN$3.70. Please address the following:

 • Describe to us your relationships with the investors who participated
in the cash sales of your common stock during that period, including whether you considered them independent unrelated parties
of the company.

 • Explain to us how you determined the fair value of your common stock
at each of the issuance dates during the period, and tell us the amount of and how you calculated any compensation expense you
recorded relating to each issuance.

 • In light of the significant difference between the estimated fair
values of your common stock during the period and the estimated IPO mid-point price, please explain to us each significant factor,
including events in the history of the company's operations and capitalization, that contributed to the difference between the
recent valuations of your common stock leading up to the IPO and the estimated offering

We note your comment.
As discussed below, we have revised some of our disclosure in Amendment No. 3 in connection with this issue.

Additionally, we point
out that all option issuances occurred on May 27, 2020. We understand the request for an explanation of the determination of fair
market value of our common shares on the date of the option issuances. We set out below our response to the issues raised in your
comment by addressing (A) the relationship with the recipients of the equity issuances and how the fair market value was determined
for those issuances and (B) the difference between the fair market value for our recent equity issuances and estimated per share
price in the initial public offering being registered in Amendment No. 3 (the “IPO”).

 A. Relationship and determination of fair market value

We set out in Item 7
of Part II of Amendment No. 3 the issuances of equity securities that we have made since March 1, 2020. During that time, we issued
(a) 1,034,550 common shares in a rolling private placement (the “Private Placement”) pursuant to Regulation S under
the Securities Act of 1933, as amended (the “Securities Act”), (b) 524,324 options to acquire common shares, (c) 205,795
common shares in exchange for services provided by an Affiliate (as defined pursuant Rule 405 under the Securities Act), (d) 77,332
common shares for services provided by non-Affiliates and (e) 31,189 common shares as a finder’s fee. We set out the relationship
to us of the beneficial owners of such equity securities as well as how we determined the fair value of our common shares at each
of the issuance dates. We have added disclosure to Amendment No. 3 to indicate the relationship between us and the persons to whom
we made an equity issuance since March 1, 2020.

 (i) On March 4, 2020, we issued 36,036 common shares for total consideration of CDN$100,000 (CDN$2.775
per share).

We issued the common shares to a person
who was not, and is not, an Affiliate. Although we issued the shares on March 4, 2020, the subscription agreement pursuant to which
the shares were issued was entered into on December 27, 2019, and the per share sales price of CDN$2.775 was set at that time.
The shares were issued once we received the funds, and the shares were issued as part of the Private Placement.

The Private Placement was carved out from
an engagement letter that we entered into on December 20, 2019 with the underwriter for the IPO. The only conditions for that carve
out were that (i) the underwriter receive the terms of the Private Placement prior to a closing, (ii) the investors enter into
a lock-up agreement (the “Lock-Up Agreement”) pursuant to which they would be prohibited from selling common shares
bought in the Private Placement until six months from the closing of the IPO (subject to standard exceptions) and (iii) the aggregate
amount of the Private Placement not exceed CDN$5 million. We provided the underwriter with the terms of the Private Placement (including
the per share price of CDN$3.70 for all subscription agreements entered into after January 20, 2020), have obtained a Lock-Up Agreement
from each of the purchasers in the Private Placement and have not exceeded CDN$5 million in the Private Placement.

The per share purchase price of CDN$3.70
in the Private Placement was determined by our management based on numerous objective and subjective factors, combined with management
judgement, including (i) our operating results and financial condition, including the Company’s level of available capital
resources, (ii) the Company’s stage of development, (iii) progress of the Company’s research and development efforts
on its electric outboard powertrain system, (iv) the impact of significant corporate events or milestones, including sales or our
boats and letters of obtaining letters of interest for our outboard powertrain system; (v) material risks related to the business,
(vi) the unprecedented economic risks posed by the Covid-19 pandemic, (vii) equity market conditions affecting comparable companies
and (viii) the likelihood and potential timing of achieving a liquidity event for the common shares, such as an initial public
offering given prevailing market sector conditions.

 (ii) On March 5, 2020, we issued 86,486 common shares for total consideration of CDN$320,000 (CDN$3.70
per share).

We issued the common shares to persons
who were not, and are not, Affiliates. The shares were issued as part of the Private Placement. We set out above, the valuation
used for the per share sales price in the Private Placement.

 (iii) On April 10, 2020, we issued 31,981 common shares to two outside service providers in exchange
for services to be provided.

The service providers to whom we issued
shares were not, and are not, Affiliates. The valuation used for the per share issuance price was the per share sales price used
in the last arms-length third-party sale of common shares. That last arms-length third-party sale was the Private Placement at
CDN$3.70 per share. We calculate the amount of such expense as CDN$118,330.

 (iv) On May 27, 2020, we granted 362,162 stock options to purchase common shares at an exercise price of CDN$3.70 per common
shares and 162,162 stock options to purchase common shares at an exercise price of CDN$2.775 per common share (together, the “Options”).

We granted 362,162 options exercisable
at CDN$3.70 to Affiliates. To determine compensation expense in connection with the option grants, we valued these options pursuant
to the Black-Scholes model using the per share price in the Private Placement of CDN$3.70 as an input for the fair market value
of the common shares. We believe that this represented the fair market value of our common shares at that time as:

 • Pursuant IFRS 2 the measurement date to be used for valuing the stock options is the grant date
of the stock option. At the grant date, management had sufficient third-party evidence from non-affiliates to support the valuation
of CDN$3.70.

 • the exercise price was determined based on the Private Placement per share price of CDN$3.70 per
share which was agreed to by us and unrelated third-parties in arm’s length transactions (and which share price was also
used after the issuance of the options for sales to non-Affiliates);

 • at the time that the Options were issued, we were a private company, our common shares underlying
were not registered under the Securities Exchange Act of 1934, as amended, and the resale of the common shares underlying the options
(the “Option Shares”) were not registered under the Securities Act. If the resale of the Option Shares are never registered
under the Securities Act, the Option holders will have to wait a minimum of six-months from whenever (if ever) they exercise the
Options to avail themselves of the exemption from registration under Rule 144 under the Securities Act (and, if still Affiliates,
they would further have to comply with the volume restrictions of Rule 144);

 • we knew that pursuant to the December 19, 2019 with the underwriter in the IPO all recipients of
the options would be required to enter into the Lock-Up Agreements (and they all have entered into such Lock-Up Agreements) that
prohibit them from selling the Option Shares for six months after the IPO;

 • the Option Shares bore a significant liquidity risk as at the time the Options were issued there
was no public market for our common shares and (over four months later) there is still no guarantee that there ever will be a public
market, let alone one with significant volume or stability (as set out in the risk factor in Amendment No. 3 entitled “The
market price of our common shares may be volatile and may fluctuate in a way that is disproportionate to our operating performance.”).
Additionally, there is no guarantee that if such significant volume and stability is established in a public market for our common
shares that it can be maintained by the time that the Option holders are no longer prohibited from selling the Option Shares under
the Lock-Up Agreements;

 • there was significant uncertainty regarding general economic conditions and the health of our industry
in particular. The Covid-19 pandemic was still relatively nascent when the Options were issued, and there were significant concerns
that it could lead to a general economic recession that would affect disposable income that would otherwise be used for leisure
and outdoor activities such as boating; and

 • at the time of the option issuances, the consummation of the IPO was uncertain (a public filing
discussing the IPO did not occur until July 2020) and neither the Company nor the underwriter had set an estimated price range
for the IPO.

We issued
162,162 options with an exercise price of CDN$2.775 to a third-party consultant who performed employee-like services as set out
in a contract that we entered into with him on August 20, 2019. These options were committed to be issued at that exercise price
pursuant to that contract. We arrived at the exercise price of CDN $2.775 by virtue of private placements to non-Affiliates being
pursued by us at the time we entered into the contract at CDN$2.775. Pursuant to IFRS 2, the measurement date to be used for valuing
the stock options is the grant date of the stock option, and the date at which the issuer and another party (including an
employee) agree to a share-based payment arrangement, being when the entity and the counterparty have a shared understanding of
the terms and conditions of the arrangement. Although the exercise price was fixed when we entered
into the contract in August 2019, other terms such as vesting provisions and expiry of the option was not determined until the
grant date of May 27, 2020. The options were granted on May 27, 2020, at which time we determined the fair market value to be CDN$3.70,
based on recent private placement transactions with non-affiliates. To determine the compensation expense in connection with this
option grant, we valued these options pursuant to the Black-Scholes model, using the fair market value of CDN$3.70 and an exercise
price of CDN$2.775.

 (v) In June and July 2020, we issued 357,973 common shares to 17 persons for total consideration
of CDN$1,324,500 (CDN$3.70 per share).  In connection with this issuance, we issued 31,189 common shares as a finder’s
fee.

We issued the common shares in the Private
Placement to persons who were not, and are not, Affiliates. We set out above, the valuation used for the per share sales price
in the Private Placement.

The shares issued as the finder’s
fee were issued to a person who was not an Affiliate (although such person later became an Affiliate solely as a result of purchasing
shares equal to 10.6% of our outstanding common shares).

 (vi) In July 2020, we issued 205,795 common shares to an entity beneficially owned by our Chief Financial
Officer pursuant to a Consulting Agreement entered into on August 1, 2019.

On August 1, 2019, we entered into a Consulting
Agreement with an entity controlled by our Chief Financial Officer. Pursuant to that agreement, we were to issue our Chief Financial
Officer 205,795 common shares upon the reaching of certain milestones. As we de

United States securities and exchange commission logo
October 5, 2020
Alexandre Mongeon
Chief Executive Officer
Vision Marine Technologies Inc.
730 Boulevard du Cure-Boivin
Boisbriand, Quebec J7G2A7, Canada
Re:Vision Marine Technologies Inc.
Amendment No. 2 to Registration Statement on Form F-1
Filed September 22, 2020
File No. 333-239777
Dear Mr. Mongeon:
            We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Amendment No. 2 to Registration Statement on Form F-1 filed September 22, 2020
Prospectus Summary, page ii
1.We note that you completed a 3.7-for-1 reverse stock split on September 3, 2020 and the
exchange of 600 Class A shares, being the entire share capital of the company, for
13,850,916 Voting Common Shares on January 20, 2020.  Please revise all share and per
share information in the filing, including the audited financial statements and the notes
thereto, to give retroactive effect to these capital structure changes. Refer to IAS
33.64, SAB Topic 4.C and PCAOB Auditing Standard 4101.
Executive Compensation, page 15
2.Please update your executive compensation disclosure to include your recently
completed fiscal year. Please refer to Item 6.B. of Form 20-F.

 FirstName LastNameAlexandre  Mongeon
 Comapany NameVision Marine Technologies Inc.
 October 5, 2020 Page 2
 FirstName LastName
Alexandre  Mongeon
Vision Marine Technologies Inc.
October 5, 2020
Page 2
Capitalization and Indebtedness, page 17
3.Please refer to Item 3.B of the Form 20-F and revise the table to address the following:
•Delete the entire assets section since these amounts do not constitute part of your
capitalization.
•Revise the liabilities section to only present your short- and long-term debt amounts
using the same captions shown on your interim balance sheet on page F-30.
•Replace the line item 'Total Liabilities and Shareholders' Equity (Deficit)' with the
caption 'Total Capitalization', as that amount will be the summation of your short-
and long-term debt and total equity (deficit).
•Include a footnote to the pro forma column of the table that explains how the
proceeds from the sale of common shares issued since March 1, 2020 were used,
including, for example, for working capital or other purposes.

Related-Party Transactions, page 50
4.We note your disclosure that the amounts due to related parties were as of February 29,
2020.  Please update to reflect a more recent date.
Note 15. Subsequent Events, page F-46
5.We note your common stock and stock option issuances for cash and services during the
period from March 2020 through September 2020.  We further note that the IPO price
range is US$8.00 to US$10.00 per common stock, with a mid-point price of US$9.00 or
CDN$12.07 per share and that the fair value of your common stock used to value the
issuances was CDN$3.70.  Please address the following:

•Describe to us your relationships with the investors who participated in the cash sales
of your common stock during that period, including whether you considered them
independent unrelated parties of the company.
•Explain to us how you determined the fair value of your common stock at each of the
issuance dates during the period, and tell us the amount of and how you calculated
any compensation expense you recorded relating to each issuance.
•In light of the significant difference between the estimated fair values of
your common stock during the period and the estimated IPO mid-point price, please
explain to us each significant factor, including events in the history of the company's
operations and capitalization, that contributed to the difference between the recent
valuations of your common stock leading up to the IPO and the estimated offering
price.

 FirstName LastNameAlexandre  Mongeon
 Comapany NameVision Marine Technologies Inc.
 October 5, 2020 Page 3
 FirstName LastName
Alexandre  Mongeon
Vision Marine Technologies Inc.
October 5, 2020
Page 3
            You may contact Beverly Singleton, Staff Accountant, at 202-551-3328 or Martin James,
Senior Advisor, at 202-551-3671 if you have questions regarding comments on the financial
statements and related matters.  Please contact Thomas Jones, Staff Attorney, at 202-551-3602 or
Asia Timmons-Pierce, Special Counsel, at 202-551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       William Rosenstadt, Esq.

CORRESP
1
filename1.htm

July 31,
2020

Division
of Corporation Finance

Office
of Manufacturing

U.S. Securities
and Exchange Commission

Washington,
D.C. 20549-4720

Via EDGAR

    Re:
    Vision Marine Technologies Inc.

    Registration Statement on Form F-1

    Filed July 9, 2020

    File No. 333-239777

Ladies and Gentleman:

This letter is in
response to the comment letter dated July 23, 2020, received from the staff of the Division of Corporate Finance (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) in which the Staff provided a comment to the registration
statement on Form F-1 (the “Registration Statement”) of Vision Marine Technologies Inc. (the “Company”)
filed with the Commission on July 9, 2020. On the date hereof, the Company has filed an amendment to the Registration Statement
on Form F-1/A (the “Amended Registration Statement”). We set forth below in bold and italics the comment in your letter
relating to the Registration Statement followed by our response to the comment.

Registration
Statement on Form F-1 filed July 9, 2020

Notes
to Financial Statements

Note
14. Subsequent Events, page F-46

 1. We note the disclosure relating to your granting 1,340,000 stock options
at an exercise price of $1.00 per share and 600,000 stock options at an exercise price of $0.75 per share to your directors, officers,
employees and consultants on May 27, 2020, but also note disclosure in the Recent Sales of Unregistered Securities on page II-1
that states such stock options were issued in June 2020. Please revise the filing to eliminate this inconsistent disclosure, or
advise us.

We note
the discrepancy in the disclosure in the Registration Statement regarding the grant date of the aggregate of 1,940,000 options
mentioned in your comment. We have changed the disclosure in Item 7 of Part II (Recent Sales of Unregistered Securities) of the
Amended Registration Statement to reflect that those options were issued on May 27, 2020.

In addition to the
above response to your comment, we hereby acknowledge that (i) the Company is responsible for the adequacy and accuracy of the
disclosure in the Amended Registration Statement, (ii) comments from the Staff do not foreclose the Commission from taking any
action with respect to the Registration Statement or the Amended Registration Statement and (iii) the Company may not assert Staff
comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United
States.

    Sincerely,

    /s/ Kulwant Sandher

    Kulwant Sandher

    Chief Financial Officer

United States securities and exchange commission logo
July 23, 2020
Alexandre Mongeon
Chief Executive Officer
Vision Marine Technologies Inc.
730 Boulevard du Cure-Boivin
Boisbriand, Quebec J7G2A7, Canada
Re:Vision Marine Technologies Inc.
Registration Statement on Form F-1
Filed July 9, 2020
File No. 333-239777
Dear Mr. Mongeon:
            We have reviewed your registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply 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 these comments, we may have additional comments.
Registration Statement on Form F-1 filed July 9, 2020
Notes to Financial Statements
Note 14. Subsequent Events, page F-46
1.We note the disclosure relating to your granting 1,340,000 stock options at an exercise
price of $1.00 per share and 600,000 stock options at an exercise price of $0.75 per share
to your directors, officers, employees and consultants on May 27, 2020, but also
note disclosure in the Recent Sales of Unregistered Securities on page II-1 that states such
stock options were issued in June 2020.  Please revise the filing to eliminate this
inconsistent disclosure, or advise us.

 FirstName LastNameAlexandre  Mongeon
 Comapany NameVision Marine Technologies Inc.
 July 23, 2020 Page 2
 FirstName LastName
Alexandre  Mongeon
Vision Marine Technologies Inc.
July 23, 2020
Page 2
            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.
            You may contact Beverly Singleton, Staff Accountant, at 202-551-3328 or Martin James,
Senior Advisor, at 202-551-3671 if you have questions regarding comments on the financial
statements and related matters.  Please contact Thomas Jones, Staff Attorney, at 202-551-3602 or
Asia Timmons-Pierce, Special Counsel, at 202-551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       William Rosenstadt, Esq.

CORRESP
1
filename1.htm

July 9,
2020

Division
of Corporation Finance

Office
of Manufacturing

U.S. Securities
and Exchange Commission

Washington,
D.C. 20549-4720

Via EDGAR

 Re: Vision Marine Technologies Inc.

Draft
Registration Statement on Form F-1

Submitted
June 2, 2020

CIK
No. 0001813783

This letter
is in response to your letter of June 26, 2020 in which you provided comments to the draft registration statement on Form F-1 (the
 “Draft Registration Statement”) of Vision Marine Technologies Inc. (the “Company”) confidentially submitted
to the U.S. Securities and Exchange Commission on June 2, 2020. On the date hereof, the Company has publicly filed a Registration
Statement on Form F-1 (the “Registration Statement”). We set forth below in bold and italics the comment in your letter
relating to the Draft Registration Statement followed by our response to the comment.

Draft
Registration Statement on Form F-1 submitted June 2, 2020

Prospectus
Summary, page ii

1. Please tell us whether you may be a
 "controlled company" under the definition of the applicable stock exchange after the offering and provide appropriate
disclosure on the prospectus cover page, prospectus summary, and risk factors to the extent appropriate.

The Company
currently does not meet the definition of a “controlled company” as set out in the Nasdaq Rules, and after the offering
described in the Registration Statement, the Company will not be a “controlled company”. Although two of our directors,
through their joint ownership of 9134-0489 Quebec Inc. and their stock options each beneficially own 47.3% of our common stock,
such directors’ percentages will further decrease after the offering. Given that the persons mentioned above will be relatively
close to the “controlled company” threshold, we have added disclosure in the Registration Statement to the risk factor
entitled “Our executive officers and directors beneficially will own approximately [ ]% of our common shares after completion
of the proposed offering” setting out that the Company could become a “controlled company” if the persons described
above were to acquire enough shares to cross that threshold and the consequences to our shareholders if we were to become a “controlled
company”.

2. Please reconcile your disclosure on
page iii that you are planning to launch the Phoenix 290 with your disclosure on page 38 regarding the launch of the Phoenix 290
at the Miami Boat Show in 2020.

We have revised
the Registration Statement to reconcile this disclosure.

3. Please balance your disclosure by disclosing
the amount of your net loss for the most recent audited and interim periods.

      1

We have
revised the disclosure in the Prospectus Summary in the Registration Statement to include our net income for the most recent audited
period and the net loss for the most recent interim period.

4. We note your disclosure that you expect
your core intellectual property contained within your outboard electric powertrain systems to form the foundation for your future
growth. Please revise your summary to disclose that the intellectual property in your powertrain systems is not protected through
patents, trademarks or copyrights.

We
have revised the Registration Statement to disclose that the intellectual property in our powertrain systems is not protected
through patents, trademarks or copyrights.

Industry
Overview, page iv

5. Please tell us whether you commissioned
any of the third-party data presented in your document.

The Company
confirms that no third-party data presented in the Draft Registration Statement or the Registration Statement was prepared for
or commissioned by the Company or its affiliates.

Business
Overview, page 20

6. We note your disclosure that approximately
90% of your sales occurred outside of Canada. Please revise to include a description of the principal geographic markets in which
your company competes. Please disclose any governmental regulations associated with those geographical markets.

We have
revised the Registration Statement to reflect that approximately 90% of our sales occurred in the United States. We believe that
the Registration Statement contains the required disclosure on governmental regulations in the United States.

Patents
and Licenses, page 27

7. We note your disclosure that you intend
to continue to file patent applications with respect to components of a powertrain that you are developing. Please disclose whether
you have any pending applications.

We have
revised the Registration Statement to reflect that although the Company intends to file patent applications with respect to components
of a powertrain that it is developing no such patent applications are currently pending.

Principal
Shareholders, page 49

8. Please revise the disclosure in the
last sentence of this section to quantify the number of record holders in the United States and the corresponding percentage of
the outstanding shares currently held in the United States. Refer to Item 7.A.2. of Form 20-F.

We have
revised the Registration Statement to disclose the requested information.

Related
Party Transactions, page 50

9. We note the disclosure in the second
paragraph of this section regarding advances from related parties. Please clarify which advances were pursuant to a written agreement
and, if applicable, file the agreements as exhibits to the registration statement.

      2

None of
the advances were pursuant to a written agreement. As noted in the Registration Statement, the holders of all of the advances have
agreed to convert the outstanding advances into common shares contemporaneously with the offering. As a result, upon the completion
of the offering we will have no further obligations in connection with the advances.

Material Income
Tax Information, page 55

10. Please refer to the captions entitled
 "Certain Canadian Federal Income Tax Considerations for Non-Canadian Holders" and "Certain Material United States
Federal Income Tax Considerations" on pages 55 and 56, respectively. Please revise to clarify that the disclosure discusses
the material federal income tax considerations

We have
revised Amendment No. to disclose the requested information.

Index
to Financial Statements, page 67

11. Please tell us the consideration given
to the requirements of Instructions to Item 8.A.4 of the Form 20-F, where audited financial statements in initial public offerings
must be no more than 12 months old at the time of filing of the registration statement. At this time, we note you have confidentially
submitted your IPO on Form F-1 that contains audited financial statements for the fiscal year ended August 31, 2019. Please advise
and comply, as applicable, with Instruction 2 to Item 8.A.4 of the Form 20-F.

Although
we believe that we could be in a position to complete public offering prior to the audited financial statements being more then
12 months old at the completion of the initial public offering, we have attached as an exhibit to the Registration Statement a
request for a waiver of the requirements of Form 20-F, Item 8.A.4.

Notes
to Financial Statements of Riopel Marine Inc. Note 2:

Basis
of preparation, page F-6

12. Please revise the note to include the
date on which your Board of Directors authorized issue of the financial statements. Your current disclosure says "on DATE".
This comment also applies to similar disclosure included in your interim financial statements on page F34.

We have
revised the Registration Statement to disclose the requested information.

Exhibits
and Financial Statement Schedules, page II-1

13. Please file as exhibits to the registration
statement the stock option agreement, lease agreements and lock-up agreements mentioned on pages 34, 48 and 62, respectively.

We have
revised the exhibit index in the Registration Statement to include these contracts.

14. Please update your exhibit index to
include employment contracts required by Item 601(b)(10) of Regulation S-K, as contemplated by Item 8 of Form F-1. In the alternative,
please tell us if these agreements are not required to be publicly filed in your home country, are not otherwise publicly disclosed,
and therefore are not filed based on Item 601(b)(10)(iii)(C)(5) of Regulation S-K

We have revised the exhibit index in the Registration
Statement to include these contracts.

      3

15. We note your disclosure that you rely
on a limited number of suppliers for key components of your products. Please tell us what consideration you have given to filing
your supply agreements with your key vendors as exhibits to your registration statement.

We do not have long-term
purchase agreements purchase with the suppliers of our key components, but rather buy those components through purchase orders
and informal arrangements. As such, there are no supply agreements for these key components that we could file as exhibits to the
Registration Statement.

Although we have addressed
this issue in the Draft Registration Statement in

 (i) our risk factor entitled “We rely on a limited number of suppliers for key components of
our finished products,” where, we state, “[a]s we purchase most of our components and parts through purchase orders
rather than long-term purchase agreements, we have not contractually secured a supply chain for these components and parts;”
and

 (ii) our risk factor entitled “Increases in costs, disruption of supply or shortage of raw materials,
in particular lithium-ion cells, could harm our business,” where, we state, “[w]e do not currently have any agreements
for the supply of batteries and depend upon the open market for their procurement,”

we have revised the Registration
Statement to make this point more explicitly and to remove the contradictory statement in the section entitled “Business
Overview – Suppliers” that holds “We maintain long-term contracts with preferred suppliers . . . .”

In addition to the above
response to your comment, we hereby acknowledge that (i) the Company is responsible for the adequacy and accuracy of the disclosure
in the Registration Statement, (ii) comments from the staff of the U.S. Securities and Exchange Commission (the “Commission”)
does not foreclose the Commission from taking any action with respect to the Registration Statement and (iii) the Company may not
assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws
of the United States.

    Sincerely,

    /s/ Kulwant Sandher

    Kulwant Sandher

    Chief Financial Officer

      4

United States securities and exchange commission logo
June 26, 2020
Alexandre Mongeon
Chief Executive Officer
Vision Marine Technologies Inc.
730 Boulevard du Cure-Boivin
Boisbriand, Quebec J7G2A7, Canada
Re:Vision Marine Technologies Inc.
Draft Registration Statement on Form F-1
Submitted June 2, 2020
CIK No. 0001813783
Dear Mr. Mongeon:
            We have reviewed your draft registration statement 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 this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 submitted June 2, 2020
Prospectus Summary, page ii
1.Please tell us whether you may be a "controlled company" under the definition of the
applicable stock exchange after the offering and provide appropriate disclosure on the
prospectus cover page, prospectus summary, and risk factors to the extent appropriate.
2.Please reconcile your disclosure on page iii that you are planning to launch the Phoenix
290 with your disclosure on page 38 regarding the launch of the Phoenix 290 at the Miami
Boat Show in 2020.
3.Please balance your disclosure by disclosing the amount of your net loss for the most
recent audited and interim periods.

 FirstName LastNameAlexandre  Mongeon
 Comapany NameVision Marine Technologies Inc.
 June 26, 2020 Page 2
 FirstName LastNameAlexandre  Mongeon
Vision Marine Technologies Inc.
June 26, 2020
Page 2
4.We note your disclosure that you expect your core intellectual property contained within
your outboard electric powertrain systems to form the foundation for your future growth.
Please revise your summary to disclose that the intellectual property in your powertrain
systems is not protected through patents, trademarks or copyrights.
Industry Overview, page iv
5.Please tell us whether you commissioned any of the third-party data presented in your
document.
Business Overview, page 20
6.We note your disclosure that approximately 90% of your sales occurred outside of
Canada.  Please revise to include a description of the principal geographic markets in
which your company competes.  Please disclose any governmental regulations associated
with those geographical markets.
Patents and Licenses, page 27
7.We note your disclosure that you intend to continue to file patent applications with respect
to components of a powertrain that you are developing. Please disclose whether you have
any pending applications.
Principal Shareholders, page 49
8.Please revise the disclosure in the last sentence of this section to quantify the number of
record holders in the United States and the corresponding percentage of the outstanding
shares currently held in the United States.  Refer to Item 7.A.2. of Form 20-F.
Related Party Transactions, page 50
9.We note the disclosure in the second  paragraph of this section regarding advances from
related parties.  Please clarify which advances were pursuant to a written agreement and,
if applicable, file the agreements as exhibits to the registration statement.
Material Income Tax Information, page 55
10.Please refer to the captions entitled "Certain Canadian Federal Income Tax Considerations
for Non-Canadian Holders" and "Certain Material United States Federal Income Tax
Considerations" on pages 55 and 56, respectively. Please revise to clarify that the
disclosure discusses the material federal income tax considerations
Index to Financial Statements, page 67
11.Please tell us the consideration given to the requirements of Instructions to Item 8.A.4 of
the Form 20-F, where audited financial statements in initial public offerings must be no
more than 12 months old at the time of filing of the registration statement.  At this time,
we note you have confidentially submitted your IPO on Form F-1 that contains audited

 FirstName LastNameAlexandre  Mongeon
 Comapany NameVision Marine Technologies Inc.
 June 26, 2020 Page 3
 FirstName LastName
Alexandre  Mongeon
Vision Marine Technologies Inc.
June 26, 2020
Page 3
financial statements for the fiscal year ended August 31, 2019.  Please advise and comply,
as applicable, with Instruction 2 to Item 8.A.4 of the Form 20-F.
Notes to Financial Statements of Riopel Marine Inc.
Note 2: Basis of preparation, page F-6
12.Please revise the note to include the date on which your Board of Directors authorized
issue of the financial statements. Your current disclosure says "on DATE". This comment
also applies to similar disclosure included in your interim financial statements on page F-
34.
Exhibits and Financial Statement Schedules, page II-1
13.Please file as exhibits to the registration statement the stock option agreement, lease
agreements and lock-up agreements mentioned on pages 34, 48 and 62, respectively.
14.Please update your exhibit index to include employment contracts required by Item
601(b)(10) of Regulation S-K, as contemplated by Item 8 of Form F-1.  In the alternative,
please tell us if these agreements are not required to be publicly filed in your home
country, are not otherwise publicly disclosed, and therefore are not filed based on Item
601(b)(10)(iii)(C)(5) of Regulation S-K
15.We note your disclosure that you rely on a limited number of suppliers for key
components of your products. Please tell us what consideration you have given to filing
your supply agreements with your key vendors as exhibits to your registration statement.
            You may contact Beverly Singleton, Staff Accountant, at 202-551-3328 or Martin
James, Senior Advisor, at 202-551-3671 if you have questions regarding comments on the
financial statements and related matters.  Please contact Thomas Jones, Staff Attorney, at 202-
551-3602 or Asia Timmons-Pierce, Special Counsel, at 202-551-3754 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       William Rosenstadt, Esq.