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                             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
 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,
FirstName LastNameAlexandre Mongeon
                                                            Division of
Corporation Finance
Comapany NameVision Marine Technologies Inc.
                                                            Office of
Manufacturing
October 28, 2020 Page 2
cc:       William Rosenstadt, Esq.
FirstName LastName