September 17, 2024

Shaun Passley
Chief Executive Officer
ZenaTech, Inc.
69 Yonge St. Suite 1404
Toronto, Ontario Canada M5E 1K3

       Re: ZenaTech, Inc.
           Amendment No. 9 to Registration Statement on Form F-1
           Filed September 6, 2024
           File No. 333-276838
Dear Shaun Passley:

     We have reviewed your amended registration statement and have the
following
comments.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless we
note otherwise,
any references to prior comments are to comments in our September 3, 2024
letter.

Amendment No. 9 to Registration Statement on Form F-1
Consolidated Income Statements of Comprehensive Loss Expressed in Canadian
dollars, page
142

1.     We have reviewed your response to prior comment 3. In addition, you have
revised the
       weighted average common shares outstanding to 16,980,325, which no
longer equals the
       basic number of common shares outstanding of 17,016,499. Please provide
a
       reconciliation of the numerators and the denominators of the basic and
diluted per-share
       computations. Refer to Paragraph 70 of IAS 33.
Item 8. Exhibits and Financial Statement Schedules
Ex-23.2 Auditor's Consent March 31, 2024, page 208

2.     In your next amendment, please have your independent registered public
accounting firm
       update the consent in Exhibits 23.2 to explicitly reference the most
recent amendment
 September 17, 2024
Page 2

       number (e.g.,    Amendment No. 10 to the Registration Statement on Form
F-1   ).
       Please contact Amanda Kim at 202-551-3241 or Stephen Krikorian at
202-551-3488 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Jan Woo at 202-551-3453 with
any other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Technology
cc:   Karim Lalani