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CORRESP
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CORRESP

 [AquaBounty Technologies, Inc. Letterhead]

August 19, 2014

 VIA EDGAR

Division of Corporation Finance

 Securities and Exchange
Commission

 100 F Street N.E.

 Washington, D.C. 20549

Attention: Jennifer Thompson

Re:
AquaBounty Technologies, Inc.

 Amendment No. 1 to Form 10-12B

Filed April 25, 2014

File No. 001-36426

 Ladies and
Gentlemen:

 Set forth below are the responses of AquaBounty Technologies, Inc. (the “Company”) to the comments of
the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) Division of Corporation Finance contained in the Staff’s letter dated August 6, 2014 relating to Amendment
No. 1 to the Company’s Registration Statement on Form 10 (“Amendment No. 1”). We are also filing simultaneously herewith Amendment No. 2 (“Amendment No. 2”) to the Registration
Statement on Form 10 (the “Registration Statement”). Capitalized terms used but not defined herein have the meanings set forth in the Registration Statement. For reference, the Staff’s comments are provided below in bold
immediately prior to the Company’s responses.

 General

Item 1. Business, page 3

 Overview, page 3

 Securities and Exchange Commission

August 19, 2014

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1.
Refer to the Center for Veterinary Medicine Guidance for Industry #132, The Administrative New Animal Drug Application Process, available on the FDA website. You state here that you “have completed all sections
of the New Animal Drug Application, or NADA, process with . . . the FDA, for AquAdvantage® Salmon, but are still waiting for formal approval of the NADA,” and you state on page 8 that
“[b]y 2010, [you] had completed all of the technical submission requirements for approval under the NADA.” It is our understanding that under FDA guidelines, a full NADA is not deemed submitted until all of its technical sections have been
completed. Please reconcile this with your disclosure that you submitted a NADA in 1995 and ensure that you present in your revised disclosure a complete summary of the FDA’s phased review process and the process for submitting and obtaining
approval for an Administrative NADA from the FDA.

 Response:

The Company advises the Staff that it opened an Investigational New Animal Drug (the “INAD”) file with the FDA in 1995.
The INAD was opened because, at that time, there was no defined regulatory framework for the regulation of genetically engineered animals. Thereafter, the Company began working with the FDA’s Center for Veterinary Medicine (the
“CVM”) on the submission of studies that the Company presumed would be part of the eventual regulatory process. The Company understands that CVM further presumed that the eventual regulatory process would be under the
authority granted to the FDA in the Federal Food, Drug, and Cosmetic Act of 1938. In January 2009, the FDA published its Final Guidance Document No. 187 in the Federal Register. Final Guidance Document No. 187 clarified the FDA’s view
of its authority for regulation of genetically modified animals.

 This phased review process, which included a cycle of study conduct,
submission, review and acceptance, continued over the period from 1995 to 2010. Under this process, the Company submitted studies to the CVM responsive to each technical NADA section. These technical sections required submission of studies,
information and other materials relating to molecular characterization of the construct, molecular characterization of AquAdvantage Salmon lineage, phenotypic characterization of AquAdvantage Salmon, a genotypic and phenotypic durability plan,
support for environmental, food and feed safety and claim validation. Specifically:

•

In August 2006, the Company submitted to the CVM the last correspondence for the review of the molecular characterization of the AquAdvantage construct. On October 6, 2006, the Company received a letter from the
CVM stating “the data and information that you have submitted adequately supports the molecular characterization of the opAFP-GHc2 construct.”

•

In May 2007, the Company submitted to the CVM the last correspondence for the review of the molecular characterization of the AquAdvantage Salmon lineage. On July 2, 2008, the Company received a letter from the CVM
stating “[w]e have reviewed the data and information you have submitted in support of the molecular characterization of the genetically engineered (GE) salmon referred to as ‘AquAdvantage Salmon’ and find that it is adequate support
to conclude the molecular characterization of the inserted rDNA construct and GE animal lineage step of our review.”

 Securities and Exchange Commission

August 19, 2014

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•

In July 2009, the Company submitted to the CVM the last of the correspondence for the review of the AquAdvantage Salmon claim validation. On March 12, 2010, the Company received a letter from the CVM stating
“[w]e have reviewed the data and information that you have submitted in support of the Claim Validation of the genetically engineered (GE) salmon referred to as ‘AquAdvantage Salmon’, and consider this section complete.”

•

In December 2009, the Company submitted to the CVM the last of the correspondence for the review of the phenotypic characterization of AquAdvantage Salmon. On June 4, 2010, the Company received a letter from the
CVM stating “[w]e have reviewed the data and information that you have submitted in support of the phenotypic characterization of the genetically engineered (GE) salmon referred to as ‘AquAdvantage Salmon’ and find that it is adequate
support to conclude the phenotypic characterization step of our review.”

•

In March 2010, the Company submitted to the CVM the final correspondence for the review of the data submitted in support of the safety of food from AquAdvantage Salmon. On August 27, 2010, the Company received a
letter from the CVM stating “[w]e have reviewed the data and information that you have submitted in support of the food safety assessment of food from the genetically engineered (GE) salmon referred to as ‘AquAdvantage Salmon’ and
find that it is adequate to conclude our evaluation of food safety.”

•

In April 2010, the Company submitted to the CVM the last of the correspondence for the review of the genotypic and phenotypic durability of AquAdvantage Salmon. On June 11, 2010, the Company received a letter from
the CVM stating “[w]e have reviewed the data and information that you have submitted in support of the Genotypic and Phenotypic Durability of the genetically engineered (GE) salmon referred to as ‘AquAdvantage Salmon’ and find that
you have adequately supported the Genotypic and Phenotypic Durability step of our review.”

 Accordingly, by the Spring of 2010, the
Company had submitted to the CVM data for each technical submission requirement for approval under the NADA. By the Fall of 2010, the Company had received from the CVM technical section complete letters for each submission requirement.

Once all of the technical submissions had been received and reviewed by the CVM, the FDA posted its findings on its website and scheduled a
meeting of the Veterinary Medicine Advisory Committee (the “VMAC”) on September 20, 2010. The VMAC was a group of independent experts charged with providing scientific advice to the FDA on animal drug and food issues.
This meeting signaled the conclusion of the review of the technical phases of the application.

 Securities and Exchange Commission

August 19, 2014

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 The remaining items in the NADA review process include: (i) the environmental assessment
for the application, which the FDA published in December 2012, (ii) the Final Label and Package Insert, which was submitted on July 23, 2014; and (iii) a catch-all item called “all other information”, under which the Company
is required to submit to CVM all other information, not included in any of the other technical sections, that is pertinent to an evaluation of the safety or effectiveness of AquAdvantage Salmon. The Company’s latest supplement to the “all
other information” portion of the NADA was submitted to the CVM on March 13, 2014.

 The NADA is currently subject to
administrative review by the FDA. As disclosed in the Registration Statement, the Company is awaiting a final decision from the FDA on the NADA for AquAdvantage Salmon.

The Company has revised its disclosure on page 3 of Amendment No. 2 to reflect that it has completed all technical sections of the NADA
and on pages 8 through 10 of Amendment No. 2 to provide a summary of the FDA’s phased review process and the process for submitting and obtaining approval for the NADA.

2.
Please disclose and briefly describe each of the technical sections you have submitted or intend to submit to the FDA and for each technical section disclose whether you have received a technical section complete
letter. Please also disclose whether you have received any written conclusions of non-acceptance of data submitted for any technical section.

Response:

 The Company advises the Staff
that it has completed all of the technical sections of the NADA. A brief summary of the submission of each section and the receipt of the section complete letters is included in the response to comment 1. The Company also informs the Staff that it
has not received any written conclusions from CVS of non-acceptance of data submitted for any technical section of the NADA or for the environmental assessment.

The Company has revised its disclosure on page 9 of Amendment No. 2 to reflect the submission of each section, the receipt of the section
complete letters and the fact that it has not received any written conclusions of non-acceptance of data.

3.
We note your disclosure on page 4 that you entered into a contract research agreement with Tethys Aquaculture Canada, Inc., to provide you with the resources required for your development needs. Please file this
agreement as an exhibit, or tell us why you do not believe it is material to your business.

 Response:

The Company acknowledges the Staff’s comment and respectfully submits that the contract research agreement with Tethys Aquaculture Canada,
Inc., which is doing business as the Center for Aquaculture Technologies Canada, has previously been filed as Exhibit 10.15 to Amendment No. 1.

 Securities and Exchange Commission

August 19, 2014

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 The Aquaculture Industry, page 4

4.
We note your response to our prior comment 7 and reissue in part. Please address the risks associated with the piscine reovirus. Additionally, we note your disclosure on page 6 that in 2009 you “incurred an
outbreak” of ISA. Please provide additional details regarding this outbreak and the subsequent remediation measures that were taken.

Response:

 Piscine reovirus
(“PRV”) is a newly described fish reovirus of anadromous and marine fish ubiquitous among fish in Norwegian salmon farms. It is not currently listed as one of the reportable disease agents by the Canadian Food Inspection
Agency (“CFIA”). Since PRV is only recently described (see Virology Journal 2013, 10:230, Kibenge et. al. (the “2013 Report”)), and only putatively associated with salmon disease, it is very difficult
to measure its incidence, significance or threat to populations. A report published in the Journal of Fish Diseases (see Marty, Morrison, Bidulka, and Siah, 2014) (the “2014 Report”) described the results of a study covering
a span of 39 years (from 1974 to 2013) and concluded that PRV is a benign virus that has long been present in fish in the Pacific Northwest. Importantly, the study reports that PRV was not associated with diseases of heart or skeletal muscle. As was
the case in previous activist claims regarding infectious salmon anemia virus in Pacific salmon species, the claims of PRV-induced disease appear to be unfounded in light of the study described in the 2014 Report. The study also refutes the
inference in the 2013 Report that PRV may be the causative agent for the heart and skeletal diseases. The Company’s hatchery on Prince Edward Island, Canada is a closed facility which is routinely screened by CFIA and the Canadian Department of
Fisheries and Oceans (“DFO”) for fish diseases or the presence of organisms known to cause reportable disease in fish. To date, the results of testing conducted by the Company, CFIA and DFO has not indicated the presence of
PRV in its stocks. In any event, given the conclusions described in the 2014 Report, the Company does not believe that PRV presents a risk to its current or future stocks. Notwithstanding, in response to the Staff’s comment, the Company has
revised the disclosure on pages 6 and 7 of Amendment No. 2 to state that there are other diseases or health management issues, in addition to ISA and sea lice, that have impacted and may in the future impact salmon populations is certain
farming geographies.

 In addition, the Company has revised the disclosure on page 6 of Amendment No. 2 to provide additional detail
regarding the ISA outbreak in the Company’s hatchery in 2009. The Company has also supplementally provided a copy of the 2014 Report for the Staff’s review.

Our Markets, page 8

5.
Refer to the second paragraph of this section. Please discuss the basis for your beliefs with respect to cost of production and your expectation that your eggs will “sell at a premium to standard Atlantic salmon
eggs.” Please ensure that all beliefs in your revised disclosure have a reasonable basis. We note in this regard the stage of development of AquAdvantage® Salmon that you have not
received FDA approval for sale of this product, and the lack of historical revenues derived from this product.

 Securities and Exchange Commission

August 19, 2014

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 Response:

The Company believes that once it receives FDA approval for its AquAdvantage Salmon eggs, it will be able to sell the eggs to Atlantic salmon
farmers for a premium to current market prices. This belief is based on the fact that AquAdvantage Salmon grows faster than conventional Atlantic salmon, which presents a cost benefit to farmers who grow it to harvest size. Since AquAdvantage Salmon
grows to harvest size more quickly than conventional Atlantic salmon, over time, a farmer can spreads its fixed costs over a greater number of fish. Additionally, less time in the water means less cost for variable inputs, such as manpower and feed.
The Company believes that the cost benefits to the farmer associated with AquAdvantage Salmon eggs will outweigh any potential costs associated with market acceptance risk.

The Company has revised the disclosure on page 8 of Amendment No. 2 to describe these factors.

Regulatory Approval, page 8

6.
Refer to the Chairman’s Report and transcript of the Veterinary Medicine Advisory Committee Meeting, each available on the FDA website. You state that in September 2010, the Committee concluded that
“AquAdvantage® Salmon is indistinguishable from other farmed Atlantic salmon, is safe to eat and does not pose a threat to the environment under the conditions in which it would live and
be harvested.” Please place this disclosure in context by briefly describing the role and authority of the Committee in the FDA approval process. Please also balance this by disclosing that the panel did not vote or make a recommendation on
whether to approve your product for human consumption, and that panel members stated your product would need additional monitoring to determine whether the growing conditions could cause health abnormalities.

Response:

 The Company advises the Staff
that the VMAC, which was a group of outside experts whose purpose was to offer its opinion on animal drug and food issues to the FDA, had no authoritative power regarding the approval of an NADA. Instead, the VMAC was convened to listen to the
results of the FDA review process and to provide an outside opinion on the FDA’s conclusions. In the case of AquAdvantage Salmon, the FDA convened the VMAC in September