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March 27, 2023
Nathan Givoni
Chief Executive Officer
Gelteq Limited
Level 4
Level 4 100 Albert Road
South Melbourne VIC, 3025
Australia
Re:Gelteq Limited
Amendment No. 3 to Registration Statement on Form F-1
Filed March 17, 2023
File No. 333-267169
Dear Nathan Givoni:
            We have reviewed your registration statement and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Amendment No. 3 to Registration Statement on Form F-1 filed March 17, 2023
Prospectus Summary
The Offering, page 9
1.We note your response to our prior comment 2 and your revised disclosure on page 9
which states that the selling shareholders will be able to sell their Ordinary Shares
"following their respective lock-up periods." However, page 130 continues to state that
the selling shareholders "are not subject to lock-up agreements." Please reconcile
throughout both the primary and resale prospectus. In the event the selling shareholders
are, in fact, subject to lock-up periods, please include this information in the resale
prospectus.

 FirstName LastNameNathan Givoni
 Comapany NameGelteq Limited
 March 27, 2023 Page 2
 FirstName LastNameNathan Givoni
Gelteq Limited
March 27, 2023
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
45
2.We note your response to prior comment 3.  We further note that you added disclosure
that “Cumulatively, through March 1, 2023, approximately 24% of total units ordered
were from related parties.”  Please revise your filing to quantify your total orders for the
period July 1, 2022 to March 1, 2023 and separately quantify the amount of orders from
related parties.
Critical Accounting Estimates and Judgements
Revenue Growth and the Recoverability Rate of Intangible Assets, page 56
3.We note from your revised disclosure in response to prior comment 4 that intangible
assets comprised approximately 87% of the company’s assets.  This does not appear
mathematically accurate given that as of June 30, 2022, your intangible assets were AU$
22.7 million and your total assets were AU$ 23.4 million.  Please revise your filing
accordingly.
Financial Statements, page F-1
4.We note from your disclosures on page F-16 that your financial statements are presented
in Australian dollars.  Additionally we note that when presenting Australian dollars you
have used the currency abbreviations AUD, AUD$, AU$, A$ and $.   When referring to
United States dollars you have used various currency abbreviations including $.  In order
for investors to clearly determine the currencies presented, please revise your filing to
define and present all currency abbreviations in a consistent manner.  Ensure that your
revised presentation does not use the same currency symbol for different currencies.
Exhibits
5.We note that the legal opinion filed as Exhibit 5.1 does not opine as to the validity of the
Resale Shares. Please revise. See Section II.B.2.h. of Staff Legal Bulletin No. 19.
General
6.Please revise the cover pages of both the primary and resale prospectuses to clearly state,
if true, that selling shareholders may not commence their resale of shares until after the
IPO closes. If this is not the case, please clarify.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

 FirstName LastNameNathan Givoni
 Comapany NameGelteq Limited
 March 27, 2023 Page 3
 FirstName LastName
Nathan Givoni
Gelteq Limited
March 27, 2023
Page 3
            You may contact Eric Atallah at 202-551-3663 or Al Pavot at 202-551-3738 if you have
questions regarding comments on the financial statements and related matters.  Please contact
Arzhang Navai at 202-551-4676 or Laura Crotty at 202-551-7614 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Life Sciences
cc:       Richard I. Anslow, Esq.