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SEC Company Response from Edesa Biotech, Inc. (EDSA) (CIK 0001540159) (EDSA) — May 9, 2018

Edesa Biotech, Inc. (EDSA) (CIK 0001540159)
Date: May 9, 2018 · CIK: 0001540159 · Accession: 0001144204-18-026390

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File numbers found in text: 333-224314

Date
May 9, 2018
Author
Not clearly detected
Form
CORRESP
Company
Edesa Biotech, Inc. (EDSA) (CIK 0001540159)

Letter

Attention: Ada D. Sarmento and Suzanne Hayes Division of Corporation Finance Washington, D.C. 20549 RE: Stellar Biotechnologies, Inc. (the “Company”) Registration Statement on Form S-1 (the “Registration Statement”) File Number 333-224314

Dear Mses. Sarmento and Hayes:

The Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of the effectiveness of the Registration Statement that such Registration Statement will become effective as of 5:00 P.M. on Thursday, May 10, 2018, or as soon thereafter as practicable.

The Company hereby acknowledges that:

· Should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority, declare the Registration Statement effective, the Commission is not foreclosed from taking any action with respect to the Registration Statement;

· The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

· The Company may not assert 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.

Very truly yours,
STELLAR BIOTECHNOLOGIES, INC.

Show Raw Text
CORRESP
1
filename1.htm

Stellar Biotechnologies, Inc.

332 E. Scott Street

Port Hueneme, CA 93041

May 9, 2018

Unites States Securities and

Exchange Commission

Attention: Ada D. Sarmento and Suzanne Hayes

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

 RE: Stellar Biotechnologies, Inc. (the “Company”)

Registration
Statement on Form S-1 (the “Registration Statement”)

File
Number 333-224314

Dear Mses. Sarmento and Hayes:

The Company hereby
requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of the effectiveness of the
Registration Statement that such Registration Statement will become effective as of 5:00 P.M. on Thursday, May 10, 2018, or as
soon thereafter as practicable.

The Company hereby acknowledges that:

 · Should the Securities and Exchange Commission (the “Commission”) or the Staff, acting pursuant to delegated authority,
declare the Registration Statement effective, the Commission is not foreclosed from taking any action with respect to the Registration
Statement;

 · The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement
effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration
Statement; and

 · The Company may not assert 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.

    Very truly yours,

    STELLAR BIOTECHNOLOGIES, INC.

    By:
    /s/ Kathi Niffenegger

    Name: Kathi Niffenegger
Title:   Chief Financial
Officer