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Mail Stop 6010         February 4, 2008  Mr. Carl Spana, Ph.D. President and Chief Executive Officer Palatin Technologies, Inc. 4C Cedar Brook Drive  Cranbury, NJ 08512
 Re: Palatin Technologies, Inc.
Form 10-K for Fiscal Year ended June 30, 2007 Filed September 13, 2007
 File No. 1-15543

Dear Mr. Spana:

We have reviewed your filing and have the following comments. In our
comments, we ask you to provide us with  information to better understand your
disclosure. Where a comment requests you to  revise disclosure, the information you
provide should show us what the revised disc losure will look like and identify the annual
or quarterly filing, as appli cable, in which you intend to first include it. If you do not
believe that revised disclosure  is necessary, explain the reason in your response. After
reviewing the information provided, we may raise additional comments and/or request
that you amend your filing.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the year ended June 30, 2007

Item 1.  Business

Patents and Proprietary Information, page 6

Mr. Carl Spana
Palatin Technologies, Inc.
February 4, 2008 Page 2

1. We note your disclosure that you own issu ed patents relating to Bremelanotide
and NeutroSpec, and that you license cer tain patents relating to compounds and
methods of treatment for sexual dysfuncti on.  Please expand your disclosure to
describe the nature of these patents an d their duration, as required by Item 101
(c)(1)(iv) of Regulation S-K.

Item 15.  Exhibits and Financial Statement Schedules

2. We note the following agreements have been  described but not filed as exhibits:
• Exclusive license agreement with Th e Wistar Institute of Biology and
Anatomy;
• License agreement with Competitive Technologies, Inc.

Please file these agreements as exhibits or provide us with an analysis supporting
your determination that the agreements ar e not required to be  filed pursuant to
Item 601 (b)(10) of Regulation S-K.  Please note that if these agreements were
filed previously, you may amend your Form  10-K to incorporate the previously-
filed agreement by reference.

* * * * *

 Please respond to these comments within 10 business days or tell us when you
will provide us with a response. Please provide us any requested information. Detailed cover letters greatly facilitate  our review. Please file the letter on EDGAR under the form
type label CORRESP.    We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:  ‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
‚ the company may not assert staff comments as a defense in any proceeding initiated

Mr. Carl Spana
Palatin Technologies, Inc. February 4, 2008 Page 3

by the Commission or any person under the federal securities laws of the United
States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.     Please do not hesitate to contact Rose Zukin at (202) 551-3239 or me at (202) 551-3715 if you have questions regarding th e comments and related matters.

Sincerely,

Jeffrey Riedler Assistant Director