SecProbe.io

May 1, 2018
Kathi Niffenegger
Chief Financial Officer
Stellar Biotechnologies, Inc.
332 E. Scott Street
Port Hueneme, CA 93041
Re:Stellar Biotechnologies, Inc.
Registration Statement on Form S-1
Filed April 17, 2018
File No. 333-224314
Dear Ms. Niffenegger:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If 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 reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-1
Cover Page
1.Please revise the cover page to provide the date that the offering will end.  Refer to Item
501(b)(8)(iii) of Regulation S-K.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration

 FirstName LastNameKathi Niffenegger
 Comapany NameStellar Biotechnologies, Inc.
 June 16, 2017 Page 2
 FirstName LastName
Kathi Niffenegger
Stellar Biotechnologies, Inc.
May 1, 2018
Page 2
statement.
            Please contact Ada D. Sarmento at 202-551-3798 or Suzanne Hayes at 202-551-3675
with any questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Barbara Jones, Esq.