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                                July 10, 2020

       James Nathanielsz
       Chief Executive Officer
       Propanc Biopharma, Inc.
       302, 6 Butler Street
       Camberwell, VIC, 3124 Australia

                                                        Re: Propanc Biopharma,
Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed June 26, 2020
                                                            File No. 333-238240

       Dear Mr. Nathanielsz:

             We have reviewed your amended registration statement and have the
following
       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.
Unless we note
       otherwise, our references to prior comments are to comments in our May
27, 2020 letter.

       Form S-1 filed June 26, 2020

       Cover Page

   1.                                                   We note your response
to our prior comment 1 and reissue it in part. Please revise your
                                                        registration statement
to clarify, if true, that this is a secondary offering. In this regard, we
                                                        note that some of your
disclosures indicate that are conducting a primary offering of your
                                                        securities rather than
registering a resale transaction. For instance, and without limitation,
                                                        we note your disclosure
on page 39 that the company is offering certain securities and on
                                                        page 41 where you
discuss the company's use of offering proceeds.
 James Nathanielsz
FirstName  LastNameJames
Propanc Biopharma,  Inc. Nathanielsz
Comapany
July       NamePropanc Biopharma, Inc.
     10, 2020
July 10,
Page  2 2020 Page 2
FirstName LastName
Selling Stockholder, page 66

2.       We refer to prior comment 2. Please revise to identify the
individual(s) with dispositive
         and voting control over the Ionic Ventures shares.
       Please contact Courtney Lindsay at (202) 551-7237 or Joseph McCann at
(202) 551-6262
with any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Life
Sciences