August 22, 2018

Carl Spana, Ph.D.
President and Chief Executive Officer
Palatin Technologies, Inc.
4B Cedar Brook Drive
Cranbury, New Jersey 08512

       Re: Palatin Technologies, Inc.
           Registration Statement on Form S-3
           Filed August 17, 2018
           File No. 333-226905

Dear Dr. Spana:

       We have limited our review of your registration statement to those
issues we have
addressed in our comment.

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

Registration Statement on Form S-3 filed August 17, 2018

General

1.     We note that you filed this registration statement more than 45 days
after the end of your
       fiscal year. As you do not appear to meet the age of financial statement
requirements of
       Rule 8-08(b) of Regulation S-X, you will need to include your audited
financial
       statements or file and incorporate by reference your Form 10-K for
fiscal year ended June
       30, 2018 before we will accelerate the effective date of your
registration statement. For
       additional guidance, please refer to Section 1220.3 of the Division's
Financial Reporting
       Manual.
 Carl Spana, Ph.D.
Palatin Technologies, Inc.
August 22, 2018
Page 2



        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.

       Please contact Irene Paik at 202-551-6553 or Mary Beth Breslin at
202-551-3625 with
any questions.



                                                           Sincerely,
FirstName LastNameCarl Spana, Ph.D.
                                                           Division of
Corporation Finance
Comapany NamePalatin Technologies, Inc.
                                                           Office of Healthcare
& Insurance
August 22, 2018 Page 2
cc:       Faith L. Charles, Esq. - Thompson Hine LLP
FirstName LastName