September 5, 2018

Lisa Walters-Hoffert
Chief Financial Officer
Dar  Bioscience, Inc.
3655 Nobel Drive, Suite 260
San Diego, CA 92122

       Re: Dar  Bioscience, Inc.
           Registration Statement on Form S-3
           Filed August 24, 2018
           File No. 333-227019

Dear Ms. Walters-Hoffert:

       We have limited our review of your registration statement to those
issues we have
addressed in our comments. In some of our comments, we may ask you to provide
us with
information so we may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments.

Form S-3 Filed August 24, 2018

Description of Purchase Contracts , page 21

1.     We note your disclosure that you may issue purchase contracts for the
purchase or sale of
       securities that may consist of securities of third parties. Please
advise us how you
       anticipate conducting such offerings under the registration and
disclosure requirements of
       the Securities Act. For example, please advise us of the disclosure you
will provide in the
       applicable prospectus supplement or other offering materials, including,
as necessary, any
       required financial statement and non-financial statement disclosure
about the issuer of
 Lisa Walters-Hoffert
Dar  Bioscience, Inc.
September 5, 2018
Page 2
      such securities. For guidance, please refer to the Morgan Stanley & Co.,
Inc. no action
      letter (June 24, 1996) and Securities Act Sections Compliance and
Disclosure
      Interpretation 203.03.
2.    It is not clear how the purchase contracts you propose to issue should be
characterized for
      purposes of the federal securities laws. For example, the disclosure in
the filing indicates
      that these contracts obligate you to purchase from holders, and obligate
holders to sell to
      you, securities at a purchase price that may be fixed or may be
determined by a specific
      formula. The disclosure in the filing also indicates that these contracts
may require you to
      make periodic payments to the holders or for holders to make periodic
payments to you.
      Furthermore, the disclosure indicates that you may purchase contracts
separately or as part
      of units each consisting of a purchase contract and one or more
securities, including U.S.
      Treasury securities. Finally, the disclosure in the filing indicates that
these contracts may
      require the holders of the contracts to secure their obligations in a
specified manner.
      Based on this disclosure it appears that these contracts may have
characteristics associated
      with forwards, options and security-based swaps. Please provide us with
your legal
      analysis as to how these contracts should be appropriately characterized
under the federal
      securities laws.
3.    We note the reference to "other property" that may be included in the
purchase contracts.
       Please revise your disclosure to specify what other property may be
included in the
      purchase contracts.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Jeffrey Gabor at 202-551-2544 or Mary Beth Breslin at
202-551-3625
with any questions.



                                                            Sincerely,
FirstName LastNameLisa Walters-Hoffert
                                                            Division of
Corporation Finance
Comapany NameDar  Bioscience, Inc.
                                                            Office of
Healthcare & Insurance
September 5, 2018 Page 2
cc:       Jenna Stewart, Esq.
FirstName LastName