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                           February 28, 2024

       Andrew Thut
       Chief Executive Officer
       4Front Ventures Corp.
       7010 E. Chauncey Lane, Suite 235
       Phoenix, AZ 85054

                                                        Re: 4Front Ventures
Corp.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2022
                                                            Response dated
February 7, 2024
                                                            File No. 000-56075

       Dear Andrew Thut:

              We have reviewed your February 7, 2024 response to our comment
letter and have the
       following comments.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our January 30,
       2024 letter.

       Form 10-K for Fiscal Year Ended December 31, 2022

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Non-GAAP Financial and Performance Measures
       Adjusted EBITDA, page 38

   1.                                                   We note your response
to prior comment 1. It is unclear from your response why
                                                        accounting for a failed
lease back transaction under US GAAP, as though it did not fail,
                                                        does not constitute an
individually tailored recognition method under Question 100.04 of
                                                        the Compliance and
Disclosure Interpretations (   C&DIs   ) for Non-GAAP Financial
                                                        Measures. Please
specifically tell us how you considered the guidance of Question 100.04
                                                        in determining that
your presentation does not constitute an individually tailored
                                                        recognition method or
remove this adjustment from future filings.
 Andrew Thut
FirstName LastNameAndrew   Thut
4Front Ventures Corp.
Comapany28,
February  Name4Front
            2024      Ventures Corp.
February
Page 2 28, 2024 Page 2
FirstName LastName
2.       We note your response to comment 2 and that you believe that your
Matteson facility
         charges are not normal, recurring, cash operating expenses necessary
to operate your
         business. We note that your company appears to be growing and that you
will continue to
         construct new facilities as you grow. You further state your Matteson
facility charges have
         historically varied from period to period and are based on factors
largely outside of your
         control, such as labor costs and rates of inflation. It appears you
are trying to normalize
         your costs. Considering these factors outlined, please explain to us
in more detail how
         you considered if the Matteson facility start-up costs are normal,
recurring, cash operating
         expenses necessary to operate your business. Refer to the guidance in
Questions 100.01 of
         the C&DIs for Non-GAAP Financial Measures.
3.       We note from your response to prior comment 3 that you have excluded
$3.8 million of
         litigation funding from your adjusted EBITDA. However, your proposed
disclosures in
         response to comment 3 in our letter dated December 15, 2023 does not
appear to exclude
         the litigation funding from adjusted EBITDA. Please address the
following:

                Clarify if the $3.8 million litigation funding is included in
your Adjusted EBITDA
              subtotal for the year ended December 31, 2022.
                If litigation funding is not included in your Adjusted EBITDA
subtotal, tell us which
              line item in your Adjusted EBITDA reconciliation includes the
adjustment to remove
              this amount; and
                If the litigation funding is not included, please explain to us
why you did not include
              this funding in your measure.
4.       We note your response to prior comment 4 and please address the
following related to
         your Adjusted EBITDA reconciliation:

                Tell us how the $7.4 million Employee Retention Tax Credit
disclosed on pages 38
              and F-37 is accounted for in your adjusted EBITDA presentation.
If this amount is
              included in your Adjusted EBITDA, tell us how you considered the
guidance of
              Question 100.03 of the C&DIs for Non-GAAP Financial Measures.
                Explain why you are including bad debt expense within your
Adjustments for
              acquisition, transaction, and other non-cash costs line item.
Explain to us in more
              detail the nature of this item and tell us how you considered
Question 100.01 of the
              C&DIs for Non-GAAP Financial Measures.
5.       We note within your Form 8-K filed on November 23, 2023 that you
present non-GAAP
         financial measures, but you do not present the most directly
comparable GAAP measures
         with equal or greater prominence. For each non-GAAP financial measure
you present,
         including within your press release headlines, please present the most
directly comparable
         GAAP measure with equal or greater prominence as required by Item
10(e)(1)(i)(A) of
         Regulation S-K.
 Andrew Thut
4Front Ventures Corp.
February 28, 2024
Page 3

       Please contact Eric Atallah at 202-551-3663 or Tara Harkins at
202-551-3639 if you have
questions regarding comments on the financial statements and related matters.



FirstName LastNameAndrew Thut                             Sincerely,
Comapany Name4Front Ventures Corp.
                                                          Division of
Corporation Finance
February 28, 2024 Page 3                                  Office of Life
Sciences
FirstName LastName