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| 1430 Greg Street, Suite 501 |
| Sparks, Nevada, 89731 |
| Telephone: (775) 955-9500 |
| July 27, 2012 |
| Division of Corporation Finance |
| U.S. Securities & Exchange Commission |
| 100 F. Street, NE |
| Washington, D.C. 20549 |
| Attention: Ronald Alper |
| Dear Sir: |
| Re: | EMC Metals Corp. (the “Company”) |
| Registration Statement on Form S-1 | |
| SEC File No. 333-181271 |
Pursuant to Rule 461(a), the Company hereby requests acceleration of the effective date of the above noted registration statement to July 30, 2012 at 4:00 p.m. Eastern Time, or as soon thereafter as possible. We note that there are no underwriters or agents involved with this offering.
The Company hereby acknowledges the following:
should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
| We trust the foregoing is satisfactory. |
| EMC METALS CORP. |
| Per: | /s/ Edward Dickinson | |
| Edward Dickinson, Chief Financial Officer |