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Stellar Biotechnologies, Inc.

332 E. Scott Street

Port Hueneme, California 93041

September 26, 2016

By EDGAR

Securities and Exchange Commission

Attention: Suzanne Hayes

Assistant Director

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Stellar Biotechnologies, Inc.

    Registration Statement on Form S-3

    File No. 333-213654

Dear Ms. Hayes:

Pursuant to Rule 461 under the Securities
Act of 1933, the undersigned registrant (the “Registrant”) hereby respectfully requests that the above-referenced
Registration Statement on Form S-3 be declared effective at 4:00 p.m. (Washington, D.C. time) on Wednesday, September 28, 2016,
or as soon as practicable thereafter. An oral request for acceleration of effectiveness may be made in the future. The Registrant
is aware of its obligations under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended.

In connection with the Registrant’s
request for acceleration of effectiveness of the above-referenced Registration Statement on Form S-3, the Registrant acknowledges
that:

 · should the Securities
                                         and Exchange Commission (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 disclosure in the filing; and

 · the Registrant
                                         may not assert staff comments and the declaration of effectiveness as a defense in any
                                         proceeding initiated by the Commission or any person under the federal securities laws
                                         of the United States.

If you have any questions regarding this
request, please contact the undersigned at (805) 488-2800 or Barbara A. Jones of Greenberg Traurig, LLP at (617) 310-6064.

    Sincerely,

    STELLAR BIOTECHNOLOGIES, INC.

    By:
    /s/ Kathi Niffenegger

    Name:  Kathi Niffenegger

    Title:  Chief Financial Officer