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                           March 19, 2024

       Stephen T. Wills
       Chief Financial Officer
       Palatin Technologies, Inc.
       4B Cedar Brook Drive
       Cranbury, NJ 08512

                                                        Re: Palatin 
Technologies, Inc.
                                                            Registration 
Statement on Form S-1
                                                            Filed March 14, 
2024
                                                            File No. 333-277934

       Dear Stephen T. Wills:

              This is to advise you that we have not reviewed and will not 
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for 
acceleration. We remind you
       that the company and its management are responsible for the accuracy and 
adequacy of their
       disclosures, notwithstanding any review, comments, action or absence of 
action by the staff.

                                                        Please contact Jessica 
Dickerson at 202-551-8013 with any questions.



                                                                                
                           Sincerely,

                                                                                
                           Division of Corporation Finance
                                                                                
                           Office of Life Sciences
       cc:                                              Faith L. Charles, Esq.