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CORRESP
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  Amy L.
                         Bowler

                         Partner

                         Phone
                         303.290.1086

                         abowler@hollandhart.com

January
31, 2025

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Energy & Transportation

100
F Street N.E.

Washington,
DC 20549

  Attn:
  Michael
  Purcell

  Daniel Morris

Re: American
                                            Battery Technology Company

  Registration
                                            Statement on Form S-1

  Response
                                            dated January 16, 2025

  File
                                            No. 333-283807

Dear
Messrs. Purcell and Morris:

Set
forth below is the response of American Battery Technology Company (the “Company”) to the comment received
from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
by letter dated January 29, 2025, regarding the above-referenced Registration Statement on Form S-1 (the “Form S-1”).
For your convenience, the Company has set forth below the Staff comment followed by the Company’s response.

Response
dated January 16, 2025

General

1. We
                                            note your response to prior comment 3 and reissue in part. Please expand your disclosure
                                            as to the relationship or lack thereof between the Company and High Trail Entities. For example,
                                            please detail whether any of the High Trail Entities are an affiliate of the Company, or
                                            if any of the Company’s executive officers or directors have a relationship with the
                                            High Trail Entities.

High
Trail Investments ON LLC and High Trail Special Situations LLC (the “High Trail Entities”) have not previously been and are
not currently affiliates of the Company. The sale of the senior secured convertible notes to the High Trail Entities was negotiated in
an arm’s length transaction between the parties. None of the High Trail Entities nor any person that controls a High Trail Entity
is an officer, director, or beneficial owner of more than 4.99% of the Company’s common stock and the High Trail Entities are contractually
prohibited from holding more than 4.99% of the Company’s common stock at any time. In addition, none of the Company’s executive
officers or directors have a relationship with the High Trail Entities, other than in connection with the sale of the notes pursuant
to the Securities Purchase Agreement entered into by the Company and the High Trail Entities.

  Location
  Mailing Address
  Contact

  555 17th Street, Suite 3200
  P.O. Box 8749
  p: 303.295.8000 | f: 303.295.8261

  Denver, CO 80202-3921
  Denver, CO 80201-8749
  www.hollandhart.com

    Page 2

In
our prior response letter filed on January 16, 2025, we agreed to revise the 5.1 legal opinion to reflect the final number of shares
being registered. We respectfully request that we not be required to refile the Form S-1, provided that we file the revised opinion on
a Current Report on Form 8-K prior to submitting a request for acceleration. Please contact Bret Meich, the Company’s General Counsel,
at (775) 561-0454), or Amy Bowler, the Company’s external counsel, at (303 290-1086), if you should have any questions regarding
the response contained herein.

  Sincerely,

  /s/
  Amy L. Bowler

  Amy L. Bowler

  Partner

  Holland & Hart LLP