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Palatin Technologies, Inc. acceleration request

[PALATIN TECHNOLOGIES, INC. LETTERHEAD]

March 30, 2006

via EDGAR

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

     Attention:
     Jeffrey Riedler, Mail Stop 0309

     Assistant Director, Division of Corporate
     Finance

     Re:
     Acceleration Request for

     Palatin Technologies, Inc.

     Registration Statement on Form
     S-3

     File No. 333-132369 Filed March 13, 2006

Ladies and gentlemen:

        We respectfully request
acceleration of the effective date of our above-captioned registration statement on Form S-3 under the Securities Act of 1933, to
2:00 p.m. EST on Friday, March 31, 2006, or as soon after that as practicable. We also acknowledge the following:

     •
     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 Registrant from its full
     responsibility for the adequacy and accuracy of the disclosures in the filing; and

     •
     the company may not assert this action as a
     defense in any proceeding by the Commission or any person under the federal securities laws of the United States.

PALATIN TECHNOLOGIES, INC.

     By:
     s/ STEPHEN T.
     WILLS

     Stephen T. Wills

     Executive Vice President and

     Chief Financial Officer