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                             September 2, 2020

       Cameron Chell
       Chief Executive Officer
       Draganfly Inc.
       2108 St. George Avenue
       Saskatoon, Saskatchewan, Canada S7M 0K7

                                                        Re: Draganfly Inc.
                                                            Amendment No. 2 to
Offering Statement on Form 1-A
                                                            Filed August 20,
2020
                                                            File No. 024-11239

       Dear Mr. Chell:

             We have reviewed your amended offering 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 offering 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 offering 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
August 19, 2020 letter.

       Amendment No. 2 to Offering Statement on Form 1-A filed August 20, 2020

       Risk Factors, page 11

   1.                                                   We note your new
disclosure on page F-69 about the amount of goodwill as of December
                                                        31, 2019. Please
include a risk factor to highlight the risks concerning goodwill, such as
                                                        impairment.
       Securities Being Offered, page 51

   2.                                                   Please tell us with
specificity where you revised the disclosure in response to prior
                                                        comment 2. Please
revise to include the disclosure regarding your units and warrants
                                                        required by Item 14 of
Form 1-A.
 Cameron Chell
Draganfly Inc.
September 2, 2020
Page 2
Exhibits

3.     We note your response to prior comment 3. Please tell us why the
qualifications in (a)
       and (b) of Section 5 are necessary and appropriate for the opinion.
        You may contact Ernest Greene, Staff Accountant, at 202-551-3733 or
John Cash,
Accounting Branch Chief, at 202-551-3768 if you have questions regarding
comments on the
financial statements and related matters. Please contact Thomas Jones, Staff
Attorney, at 202-
551-3602 or Sherry Haywood, Staff Attorney, at 202-551-3345 with any other
questions.



                                                            Sincerely,
FirstName LastNameCameron Chell
                                                            Division of
Corporation Finance
Comapany NameDraganfly Inc.
                                                            Office of
Manufacturing
September 2, 2020 Page 2
cc:       Rebecca G. DiStefano, Esq.
FirstName LastName