SecProbe.io

March 23, 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 response letter dated March 4, 2011 and have the following
comment.
 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 comment applies to your facts and circumstances, please tell us why in your response.
 After reviewing the information you provide in  response to this comment, we may have
additional comments.
Form 10-K, filed September 27, 2010

Patents and Proprietary Information, page 9

1. We note your response to prior comment 2.  In regard to the patent ap plications that are
licensed to AstraZeneca, we also note your response that such pate nt applications are
confidential, non-public documents until pub lished as required under patent laws.
However, we are not asking you to identify the sp ecific patents that have been licensed to
AstraZeneca or any confidential information contained within those patents.  Rather, we
are asking for information that clarifies the general scope of your patent coverage for
your various product categories.  Accordin gly, please provide us with proposed
disclosure for future filings that reflects th e number of issued patents and pending patent
applications, and the respective jurisdicti ons, related to your compounds that target
melanocortin receptors for the treatment of  obesity, diabetes and related metabolic
syndrome.

Carl Spana Ph.D. Palatin Technologies, Inc. March 23, 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 comment, please provide 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