Campbell Mithun Tower 222 South Ninth Street Suite 2000 Minneapolis, MN 55402-3338 Tel (612) 607-7000  Fax (612) 607-7100 www.foxrothschild.com

October 18, 2018

CONFIDENTIAL SUBMISSION VIA EDGAR

Amendment No. 1 to Draft Registration Statement on Form 10-12B

Submitted September 17, 2018

CIK No. 0001401040

Ladies and Gentlemen:

This letter is confidentially submitted on behalf of DiaMedica Therapeutics Inc. (the “Company”) in response to comments of the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with respect to the Company’s Amendment No. 1 to Draft Registration Statement on Form 10-12B, as amended, confidentially submitted on September 17, 2018 (“Amendment No. 1”), as set forth in the Staff’s letter dated October 15, 2018 to Rick Pauls, Chief Executive Officer (the “Comment Letter”). The Company is concurrently confidentially submitting Amendment No. 2 to the Draft Registration Statement (“Amendment No. 2”), which includes changes to reflect a response to the Staff’s comment and other updates. In addition to addressing the comments raised by the Staff in the Comment Letter, the Company has included other revisions and updates to its disclosure in Amendment No. 2.

For the convenience of the Staff, the numbering of the paragraphs below corresponds to the numbering of the comments in the Comment Letter, the text of which we have incorporated into this response letter for convenience in italicized type and which is followed by the Company’s response. In the responses below, page number references are to Amendment No. 2.

U.S. Securities and Exchange Commission

October 18, 2018

Page 2

In addition to confidentially submitting this letter via EDGAR, we are sending via Federal Express three (3) copies of each of this letter and Amendment No. 2 (marked to show changes from Amendment No. 1).

Amendment No. 1 to Form 10 submitted September 17, 2018

Item 1. Business

Overview, page 1

RESPONSE: In response to the Staff’s comment, the Company has revised the disclosure under the Overview section of Amendment No. 2 to note that the Company has not yet filed an IND to initiate a clinical trial for DM199 in the United States and, where appropriate, to disclose the locations of the Company’s clinical trials and the foreign jurisdictions from which the Company has received approval to initiate clinical trials. See page 2 of Amendment No. 2.

The Company respectfully informs the Staff that the Company plans to focus initially for the next several years on seeking U.S. regulatory approval for DM199 for the treatment of acute ischemic stroke and chronic kidney disease and once such approval has been obtained will then decide in which other countries to seek marketing approval. Accordingly, the Company does not believe that a description of the Australian drug approval process is necessary.

Acute Ischemic Stroke, page 3

U.S. Securities and Exchange Commission

October 18, 2018

Page 3

RESPONSE: In response to the Staff’s comment, the Company has revised the disclosure on page 4 of Amendment No. 2 to delete the reference the $20 billion annual market opportunity for DM199 for the treatment of acute ischemic stroke.

DM199 Clinical Studies, page 11

RESPONSE: In response to the Staff’s comment, the Company has revised the disclosure on pages 10 and 11 of Amendment No. 2 to provide additional information regarding the clinical studies of DM199 that the Company has conducted to date, including information, to the extent available, regarding the dosages studied, the primary and secondary endpoints, any adverse events and any other resulting objective data.

RESPONSE: In response to the Staff’s comment, the Company has revised the disclosure on page 24 of Amendment No. 2 to provide additional information about the two clinical studies in patients with Type 2 diabetes, including to which indication these studies relate, what phase of development these clinical studies were intended to be, what the primary and secondary endpoints were and whether the results are needed to proceed in the development of the drug.

U.S. Securities and Exchange Commission

October 18, 2018

Page 4

RESPONSE: In response to the Staff’s comment, the Company has revised the disclosure on page 24 of Amendment No. 2 to clarify the basis for the Company’s belief that the trial in which secondary efficacy endpoints were not met was the result of serious execution errors by the contract research organization conducting the trial.

Intellectual Property, page 17

RESPONSE: In response to the Staff’s comment, the Company has revised the disclosure on page 18 of Amendment No. 2 to describe the material terms of the agreement with Catalent Pharma Solutions, LLC and has filed this agreement as an exhibit to the registration statement. The Company supplementally informs the Staff that the Company has submitted an application for confidential treatment relating to this exhibit.

Item 2. Financial Information

Commitments and Contingencies, page 50

RESPONSE: In response to the Staff’s comment, the Company has revised the disclosure on page 53 of Amendment No. 2 to describe the material terms of the agreement with Catalent Pharma Solutions, LLC, including the counter-party, the rights and obligations of each party, the royalty term and term and termination provisions. In addition, as previously mentioned, the Company has filed this agreement as an exhibit to the registration statement and has submitted an application for confidential treatment relating to this exhibit.

U.S. Securities and Exchange Commission

October 18, 2018

Page 5

Item 8. Legal Proceedings, page 63

RESPONSE: In response to the Staff’s comment, the Company has revised the disclosure on page 66 of Amendment No. 2 to disclose the information required under Regulation S-K Item 103 with respect to the litigation referenced in the Risk Factors section.

We hope the foregoing answers are responsive to your comments. Please do not hesitate to contact me by telephone at (612) 607-7287 with any questions or comments regarding this correspondence.

Very truly yours,

Amy E. Culbert