October 2, 2019 Joseph Zirkman Senior Vice President and General Counsel DIRTT Environmental Solutions Ltd. 7303 30th Street S.E. Calgary, Alberta, Canada T2C 1N6 Re: DIRTT Environmental Solutions Ltd. Registration Statement on Form 10 Filed September 20, 2019 File No. 1-39061 Dear Mr. Zirkman: 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 Technology