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    Amy
    L. Bowler

    Partner

    Phone
    303.290.1086

    abowler@hollandhart.com

March
6, 2025

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Energy & Transportation

100
F Street N.E.

Washington,
DC 20549

Attn: Brad
                                            Skinner

Re: American
                                            Battery Technology Company

                                            Form 10-K for the Fiscal Year Ended June 30, 2024

  Filed
September 23, 2024, File No. 001-41811

Dear
Mr. Brad Skinner:

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 February 25, 2025, regarding the above-referenced Form 10-K (the “2024 Form 10-K”). For your
convenience, the Company has set forth below the Staff comment followed by the Company’s response. Capitalized terms used but not
otherwise defined in this letter have the meanings ascribed to such terms in the 2024 Form 10-K.

Form
10-K for the Fiscal Year Ended June 30, 2024

Item
2. Properties, page 21

 1. Please
                                            disclose the commodity price, the metallurgical recovery factor, and the point of reference
                                            with your mineral resource table pursuant to Item 1304(d)(1) of Regulation SK.

Response:

The
Company discloses the cut-off grade (300 ppm Li) and metallurgical recover (65.7% for Li) immediately following the referenced table,
along with other cost inputs. In response to the Staff’s comment, the Company proposes including the following table in future
filings (with appropriately updated information as of the date of filing):

    Resources

    Amount (kTons)
    Grades/qualities
    Cut-off grades
    Metallurgical recovery

    Total
    LI
    LHM

    Measured mineral resources
      721,000
      510
      3,060
    702 ppm Li
    300 ppm Li
    65.7 % for Li

    Indicated mineral resources
      2,439,000
      1,380
      8,340
    565 ppm Li
    300 ppm Li
    65.7 % for Li

    Measured + Indicated mineral resources
      3,160,000
      1,890
      11,400
    596 ppm Li
    300 ppm Li
    65.7 % for Li

    Inferred mineral resources
      2,931,000
      1,610
      9,750
    550 ppm Li
    300 ppm Li
    65.7 % for Li

a)
The estimate of mineral resources was performed by RESPEC.

b)
Tonopah Flats resources are classified as Measured, Indicated, and Inferred.

c)
Mineral resources comprised all model blocks at a 300ppm ton Li cutoff that lie within an optimized pit.

d)
The estimated mineral resources include data from the 29 sampled holes.

e)
Lithium Hydroxide Monohydrate (LHM) tons were calculated using a factor of 6.0459 relative to Li.

f)
Mineral resources that are not mineral reserves do not have demonstrated economic viability. Reported information assumes lithium hydroxide
monohydrate price of $40,000/ton, metallurgical recoveries of 65.7% for Li, mining costs of $2.45/ton mined, processing costs of $11.62/ton
processed, minimum grade of 300 ppm lithium within claystone, and general and administrative costs of $0.38/ton processed, and a 33,000-ton
per day processing rate.

g)
The effective date of the estimate is December 21, 2023.

h)
Rounding may result in apparent discrepancies between tons, grade, and contained metal content.

    Sincerely,

    /s/
    Amy L. Bowler

    Amy
L. Bowler

    Partner

    Holland
& Hart LLP

    Location
    Mailing
                                            Address

                                            P.O. Box 8749

    Denver,
    CO 80201-8749

    Contact

    555
                                            17th Street, Suite 3200

    Denver,
    CO 80202-3921

    p:
                                            303.295.8000 | f: 303.295.8261

    www.hollandhart.com