SecProbe.io

February 18, 2011

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

Re: Palatin Technologies, Inc.  Form 10-K
Filed September 27, 2010 File No. 001-15543
 Dear Mr. Spana:
 We have reviewed your filing and have the following comments.    Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.
Form 10-K, filed September 27, 2010

Melanocortin Receptor-Specific Programs, page 3

1. Please provide proposed disclosu re to be included in fu ture filings regarding your
collaboration and license agreement with AstraZeneca describing the duration of the
agreement, termination provisions and the range of royalties you will be entitled to
receive.  An acceptable range of royalties is on e of the following: “single-digits,” “teens,”
“twenties,” etc.
 Patents and Proprietary Information, page 9

2. We note that you own issued United States a nd foreign patents and patent applications
pending in the United States and other countri es relating to various  formulas.  Please
provide proposed disclosure for future filings specifying the number of patents and patent applications that you have associated with  the respective product groups, the specific
foreign jurisdictions in whic h your  patents were granted or, in the case of patents
pending, submitted.  Please include in your disc ussion the patent applications that are
licensed to AstraZeneca.

Carl Spana Ph.D. Palatin Technologies, Inc. February 18, 2011 Page 2

 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure 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 by the Commission or any person under the federa l securities laws of  the United States.

Please contact Johnny Gharib at (202) 551-3170 or Daniel Greenspan at (202) 551-3623
with any questions.
Sincerely,

Jeffrey Riedler Assistant Director