SecProbe.io

April 29, 2013

Via E -mail
Peter S. Garcia
Chief Financial Officer
BioTime, Inc.
1301 Harbor Bay Parkway, Suite 100
Alameda, CA 94502

Re: BioTime, Inc.
  Registration Statement on Form S-3
Filed  April 22, 2013
  File No.  333-188066

Dear Mr. Garcia :

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.

General

1. We note that the company’s Form S -3 filed April 3, 2013 (File No. 333-187710) is
currently under r eview by the staff.  Please note that we will not be in a position to
accelerate the effectiveness of your registration statement until comment number 1 as set
forth in our letter dated April 24, 2013 regarding the inclusion of financial statements that
comply with Rule 3 -05 of Regulation S -X is resolved .

Incorporation of Certain Information by Reference, page 39

2. Please revise your disclosure to incorporate by reference all reports filed pursuant to
Section 13(a) or 15(d) of the Exchange Act since the end of your fiscal year 2012 .

We urge all persons who are responsible for the accuracy and adequacy of the discl osure
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

Peter S. Garcia
BioTime, Inc.
April 2 9, 2013
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 acceleration 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 not 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 of 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.

Please contact Karen Ubell, Staff Attorney,  (202) 551 -3873, Jennifer Riegel, Special
Counsel, at (202) 551 -3575 or me at (202) 551 -3715 with any questions.

Sincerely,

 /s/ Jeffrey P.  Riedler

Jeffrey P. Riedler
Assistant Director

cc: Via E-mail
 Richard S. Soroko
Thompson, Welch, Soroko & Gilbert LLP