January 7, 2011

Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Attn:	Kevin L. Vaughn
	Accounting Branch Chief
Re:	Universal Biosensors, Inc.
	Form 10-K for the Year Ended December 31, 2009
	Filed March 16, 2010
	File No. 000-52607

Ladies and Gentlemen:

     Reference is made to your letter of December 28, 2010 commenting on the Annual Report on Form 10-K filed by Universal Biosensors, Inc. (“Company”) for the year ended December 31, 2009 (“Form 10-K”).

     The Company acknowledges that:

• the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

• the Company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Yours truly,

 

/s/ Salesh Balak  

Salesh Balak 

Chief Financial Officer of Universal Biosensors, Inc.