SecProbe.io

August 9, 2012

Via E -mail
Ms. Judith Segall
Vice -President and Secretary
BioTime, Inc.
1301 Harbor Bay Parkway, Suite 100
Alameda, CA 94502

Re: BioTime, Inc.
  Registration Statement on Form S-3
Filed  July 31, 2012
  File No.  333-182964

Dear Ms. Segall :

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

Please respond to this letter by amending your registration statement and providing the
requested information .  Where 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 revie wing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.

Registration Statement on Form S -3

1. We note that you own 77 percent of LifeMap  Sciences, Inc., a subsidiary of your
company and also a selling stockholder.  Please revise your filing to identify  LifeMap
Sciences, Inc. as an underwriter.  This disclosure should be included on the Prospectus
Cover Page and in the Plan of Distribution.

2. You indicate in Item 16: Exhibits that the consent of Rothstein Kass is filed as exhibit
23.1 to your registration statement.  However, it does not appear that the auditor’s
consent has been filed.  In your next amendment, please file the auditor’s con sent as
exhibit 23.1.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require .  Since the company and its management are in

Ms. Judith Segall
BioTime, Inc.
August 9, 2012
Page 2

 possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request accel eration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does n ot foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company  may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act o f 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

You may contact Rose Zukin at (202) 551 -3239, Bryan Pitko at (202) 551 -3203 , or me at
(202) 551 -3710 with any questions.

Sincerely,

 /s/ Daniel Greenspan for

 Jeffrey P. Riedler
Assistant Director

cc: Richard S. Soroko, Esq.
Thompson, Welch, Soroko & Gilbert LLP
3950 Civic Center Drive, Suite 300
San Rafael, CA 94903